State of Maine v. Steven Edwards

2024 ME 55
CourtSupreme Judicial Court of Maine
DecidedAugust 1, 2024
DocketSom-23-326
StatusPublished

This text of 2024 ME 55 (State of Maine v. Steven Edwards) is published on Counsel Stack Legal Research, covering Supreme Judicial Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Maine v. Steven Edwards, 2024 ME 55 (Me. 2024).

Opinion

MAINE SUPREME JUDICIAL COURT Reporter of Decisions Decision: 2024 ME 55 Docket: Som-23-326 Argued: May 9, 2024 Decided: August 1, 2024

Panel: STANFILL, C.J., and MEAD, HORTON, CONNORS, LAWRENCE, and DOUGLAS, JJ.

STATE OF MAINE

v.

STEVEN EDWARDS

STANFILL, C.J.

[¶1] Following a jury trial, Steven Edwards was convicted of eighteen

counts of possession of sexually explicit material (Class C), 17-A M.R.S.

§ 284(1)(C) (2024).1 Edwards appeals from the judgment (Somerset County,

Mullen, C.J.). Edwards challenges the court’s denials of his motion to suppress,

1 17-A M.R.S. § 284(1)(C) (2024) provides that:

A person is guilty of possession of sexually explicit material if that person: . . . [i]ntentionally or knowingly . . . possesses or accesses with intent to view any . . . computer data file . . . or any other mechanically, electronically or chemically reproduced visual image or material that the person knows or should know depicts another person engaging in sexually explicit conduct, and:

(1) The other person has not in fact attained 12 years of age; or

(2) The person knows or has reason to know that the other person has not attained 12 years of age. 2

motion for judgment of acquittal, motions for a mistrial, and motion for a new

trial. We find no error and affirm his conviction.

I. BACKGROUND

[¶2] On January 6, 2021, Edwards entered a plea of not guilty to an

indictment charging him with nine counts of possession of sexually explicit

material (Class C) under 17-A M.R.S. § 284(1)(C). The State later filed a

superseding indictment that included nine additional counts of possession of

sexually explicit material (Class C), to which he also pleaded not guilty. All

charges were based on images found, upon execution of a search warrant, on

computers in Edwards’ possession.

[¶3] Edwards moved to suppress all evidence found on the computers,

arguing that there was no probable cause for the warrant because the

information in the affidavit supporting the application for the warrant was

stale. After a hearing on August 12, 2022, the court denied the motion to

suppress. The court found that the Maine State Police Computer Crimes Unit

received referrals from the National Center for Missing and Exploited Children

(NCMEC) alleging that on three separate dates, January 28, January 30, and

February 26, 2019, potential child exploitation material had been uploaded 3

from an IP address2 associated with a property in Mercer, Maine, later

identified to belong to Edwards. Based on these tips from NCMEC, a Computer

Crimes Unit detective presented a request for a search warrant to the court on

August 8, 2019. The search warrant was signed by the court on the same day

and executed the next day. The affidavit presented in support of the application

included the Computer Crimes Unit detective’s opinion that consumers of child

pornography often keep images or evidence of images for significant periods of

time and that even if such images are deleted, there is often evidence on the

computer demonstrating that a consumer accessed the images. The affidavit

also outlined the investigation undertaken between receipt of the tips and the

request for a warrant, including the investigation’s findings concerning the

physical location of the IP address, that Edwards resided at the house at that

location, that Edwards has an interest in child pornography, and that he had

previous convictions while in the military for possession of child pornography

and other sexual misconduct charges.

[¶4] The court held a jury trial on March 14-16, 2023. At the trial, the court

heard testimony from the detective with the Computer Crimes Unit, a special

2 According to the affidavit, the IP address “is a unique numerical label assigned to each device . . .

participating in a computer network that uses the Internet Protocol for communication. . . . Every machine that is on the internet has an IP number. Every location has a unique IP number.” 4

agent from Homeland Security Investigations who had examined Edwards’s

computers, and a computer forensics expert for the defense. The Computer

Crimes Unit detective testified that Edwards told her he had been searching for

adult pornography and that sexually explicit images came up that were

“embarrassing, young, and really bad.” Edwards also told her he “does not look

for child pornography but that there is a gray area where a little girl can look

older and an older girl can look younger.” The special agent testified that he

found in unallocated space on Edwards’s computers multiple internet search

terms that are used to search for sexually explicit images of minors. The special

agent explained that unallocated space on a hard drive is where a file is stored

when the “data is no longer needed. It’s been marked for deletion, but it’s not

yet overwritten, so it’s still resident in the spot it was in.” He also located

eighteen thumbnail images3 in unallocated space on Edwards’s computers. The

court admitted in evidence the images, the evidence log from the search of

Edwards’s house, and a photograph of Edwards’s house.

[¶5] After the State rested, Edwards moved for a judgment of acquittal,

arguing that the State had not presented evidence sufficient to support a finding

The agent testified that thumbnail images are “small pixelated images that as you zoom in on 3

them, they get more gradient” or the “pictures that are on [a website’s] landing page.” 5

that Edwards possessed the images, that he accessed the images on eighteen

separate occasions, or that the images depicted persons under the age of

twelve. The court denied the motion. After the defense rested, Edwards

renewed his motion for a judgment of acquittal; it was again denied.

[¶6] During the State’s rebuttal closing argument, purportedly referring

to the defense’s comments about the adult and “barely legal” pornography

found on Edwards’s computers, the prosecutor stated, “Can you not tell the

difference between an adult and a child? That is what this case is about. It’s not

the however many he possessed that we didn’t charge him with.” Edwards

immediately objected and requested a mistrial. The court denied the motion

for a mistrial but issued a curative instruction reminding the jury that closing

arguments are not evidence and the jury should decide the case based solely on

the evidence and the charges presented. After giving the curative instruction,

the court also asked the jury if anyone would have a problem focusing only on

the eighteen counts before them; the jurors indicated they would not.

[¶7] After having indicated to the court at the beginning of the day that

he had no objections to the jury instructions, Edwards then stated, during the

recess just prior to the court instructing the jury, that he did have a concern

about the instructions. The court stated that it would give the previously 6

agreed-upon instructions and that Edwards could object when they were given.

The court also indicated further concern about the State’s statement during

rebuttal. Edwards again objected to the jury instructions, but when the court

asked for clarity as to the nature of his objection, Edwards’s attorney did not

elaborate, responding, “It’s as clear as I can make it at this point, Judge.”

[¶8] The jury found Edwards guilty on all eighteen counts.

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2024 ME 55, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-maine-v-steven-edwards-me-2024.