State v. Buchanan

2007 ME 58, 921 A.2d 159, 2007 Me. LEXIS 60
CourtSupreme Judicial Court of Maine
DecidedMay 15, 2007
StatusPublished
Cited by9 cases

This text of 2007 ME 58 (State v. Buchanan) 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 v. Buchanan, 2007 ME 58, 921 A.2d 159, 2007 Me. LEXIS 60 (Me. 2007).

Opinion

LEVY, J.

[¶ 1] John T. Buchanan Jr. appeals from a judgment of conviction in the Superior *160 Court (Washington County, Humphrey, C.J.) resulting from a conditional guilty plea for unlawful trafficking in a scheduled drug (Class B), 17-A M.R.S. § 1103(1-A)(A) (2006); illegal importation of a scheduled drug (Class C), 17-A M.R.S. § 1118(1), (2)(A) (2006); and unlawful possession of a scheduled drug (Class D), 17-A M.R.S.A. § 1107-A(1)(C) (Supp.2004). 1 Buchanan contends that the trial court erred by ruling, prior to trial, that it would not admit evidence that Buchanan had a prescription for the drug in question, oxy-codone. Because we agree with Buchanan’s contention, we vacate the judgment.

I. BACKGROUND

[¶ 2] Buchanan, a Canadian citizen and resident of Oromocto, New Brunswick, attempted to enter Maine through the Mill-town Point of Entry near Calais on September 5, 2005. Customs officers searched Buchanan, revealing a cellophane bag containing twenty-five eighty-milligram oxycodone pills taped underneath his scrotum. 2 Following his arrest, Buchanan was indicted by the Washington County grand jury on three counts: unlawful trafficking in a scheduled drug (Class B), 17-A M.R.S. § 1103(1-A)(A); 3 illegal importation of a scheduled drug (Class C), 17-A M.R.S. § 1118(1), (2)(A); 4 and unlawful possession of a scheduled drug (Class D), 17-A M.R.S.A. § 1107-A(1)(C). 5

[¶ 3] After a jury had been selected, a hearing was held in the Superior Court at which the parties argued the admissibility of evidence that Buchanan had a prescription for oxycodone to alleviate his chronic pain. Buchanan and the State brought to the court’s attention that Buchanan intended to raise as a defense that he was in possession of a Canadian prescription for oxycodone. The State contended the court should exclude the evidence because the statute that allows a person to lawfully possess a scheduled drug that he or she “has been prescribed, sold or dispensed for *161 a legitimate medical purpose by a physician,” only applies if the drug or substance is “in use,” or “in the container in which it was delivered by the person selling or dispensing the drug or substance.” 22 M.R.S.A. § 2383-B(l) (2004). 6 See also 17-A M.R.S. §§ 1103(1-B)(A), 1107-A(2)(A), 1118(1) (2006).

[¶ 4] Buchanan did not dispute the State’s contention that his pills were not in their container and were not “in use” at the time he was searched. Rather, he asserted that he did not intend to introduce evidence of the prescription to invoke the defense of lawfully prescribed drugs pursuant to section 2382-B(l), but to raise a reasonable doubt regarding the mens rea element of the trafficking charge under section 1103(1-A)(A); that is, to defeat the State’s claim that he possessed a scheduled drug with the intent to traffick in it. 7 Buchanan contended that, because the evidence of the prescription should be found admissible as to the trafficking charge, he also intended to proceed to trial on the illegal possession and illegal importation charges “because there’s always the opportunity for a compromised verdict,” and the court could cure any problems with the limited admissibility of the evidence by “jury instructions, not by excluding the evidence.”

[¶ 5] The court ruled that because Buchanan conceded that he could not be found in lawful possession of the pills in accordance with section 2382-B(l), evidence of the prescription would not be admitted as to any of the three counts. The court noted that its ruling did not preclude Buchanan from testifying at trial that he intended to take the oxycodone “for his own personal maladies or purposes.”

[¶ 6] In response to the court’s ruling, Buchanan entered conditional guilty pleas pursuant to M.R.Crim. P. 11(a)(2), 8 preserving for appellate review the court’s denial of his request to introduce evidence of his prescription. 9 This appeal followed.

*162 II. DISCUSSION

A. Unlawful Trafficking in a Scheduled Drug

[¶ 7] Buchanan contends that evidence of a prescription for oxycodone is relevant to the question of whether he intended to unlawfully traffiek in a scheduled drug, even though he concedes that the evidence cannot be used to establish that he lawfully possessed the oxycodone pursuant to section 2383-B(l). Buchanan argues that lawful possession is not the exclusive defense to the charge of trafficking, and that the existence of a prescription is relevant to create a reasonable doubt as to whether he intended to traffiek in the oxycodone pills, a necessary element of the crime pursuant to section 1103(1— A)(A).

[¶ 8] Maine Rule of Evidence 401 provides that relevant evidence is “evidence having any tendency to make the existence of any fact that is of consequence to the determination of the action more probable or less probable than it would be without the evidence.” All relevant evidence is admissible, except as limited by the constitution, statute or court rules. M.R. Evid. 402. “A criminal defendant is entitled to admission of relevant evidence, and the court’s choice to.exclude relevant evidence is significantly limited.” State v. McMahan, 2000 ME 200, ¶18, 761 A.2d 50, 55. We review a trial court’s determination regarding the relevancy of evidence for clear error. State v. Williams, 653 A.2d 902, 906 (Me.1995). “A ‘clear error’ standard is similar to a sufficiency of the evidence standard in that it asks if the trial court’s ruling on evidentiary foundation is supported by or not inconsistent with the facts that appear in the record.” Alexander, Maine Appellate Practice § 405(e) at 186 (2005).

[¶ 9] A consequential fact in this case is Buchanan’s intent, that is, whether he possessed the oxycodone with the intent to sell, barter, trade, exchange or otherwise furnish the oxycodone for consideration. See 17-A M.R.S. § 1101(17)(C), (D) (2006). Buchanan’s lawful prescription is relevant because it may make his intent to traffiek in oxycodone less probable because it supports his assertion that he possessed the pills for a reason other than to traffiek — for his own personal use as an analgesic. Contrary to the State’s contention, the relevancy of the evidence of Buchanan’s prescription is not undermined by Buchanan’s concession that the evidence of his prescription cannot be used to establish the defense of lawful possession pursuant to section 2383-B(l) because intent is an element of the crime independent of possession.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State of Maine v. Matthew W. Pendleton
2025 ME 40 (Supreme Judicial Court of Maine, 2025)
State of Maine v. Douglas Annis
2018 ME 15 (Supreme Judicial Court of Maine, 2018)
Keybank National Association v. Estate of Eula W. Quint
2017 ME 237 (Supreme Judicial Court of Maine, 2017)
State of Maine v. Ronnie L. Reynolds
2015 ME 55 (Supreme Judicial Court of Maine, 2015)
State v. Bickart
2009 ME 7 (Supreme Judicial Court of Maine, 2009)
State v. Roberts
2008 ME 112 (Supreme Judicial Court of Maine, 2008)
State v. Dilley
2008 ME 5 (Supreme Judicial Court of Maine, 2008)

Cite This Page — Counsel Stack

Bluebook (online)
2007 ME 58, 921 A.2d 159, 2007 Me. LEXIS 60, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-buchanan-me-2007.