State v. Cuddy

366 A.2d 858, 1976 Me. LEXIS 403
CourtSupreme Judicial Court of Maine
DecidedDecember 9, 1976
StatusPublished
Cited by7 cases

This text of 366 A.2d 858 (State v. Cuddy) 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. Cuddy, 366 A.2d 858, 1976 Me. LEXIS 403 (Me. 1976).

Opinion

POMEROY, Justice.

Although appellant and his alleged companion in crime, Allan L. Bagley, a/k/a Allan L. Falloon, were indicted separately *859 for breaking, entering, and larceny (17 M. R.S.A. § 2103 1 ), the trial court, over appellant’s strenuous objections, ordered the cases consolidated for trial. A conviction of both defendants ensued.

From a judgment entered upon the jury finding of guilty, appellant has appealed. Earlier, we sustained Bagley’s appeal.

We now sustain appellant’s appeal.

Appellant bases his appeal, inter alia, upon a claim of prejudice which, as he says, resulted from the order consolidating his case with that of Bagley for trial.

The indictment alleged appellant broke into and entered a restaurant in Bingham, Maine, and therein committed larceny. The owner of the restaurant testified that he saw appellant and Bagley leave the restaurant in the early morning hours. He told the jury he followed Cuddy and Bag-ley and that he came upon them on a nearby street where they had become “stuck on a hill.” After the confrontation, the restaurant owner, appellant, and Bagley returned to the restaurant.

At trial, appellant, who was represented by counsel, did not testify. Appellant’s co-defendant, who was not represented by counsel, 2 did. He testified that neither he nor the appellant had been at the restaurant prior to the encounter on the street with the restaurant owner. When the prosecutor cross-examined Bagley, he was asked:

“Q Now, Mr. Bagley, you are also known by another name, aren’t you?
“A Allan Leroy Falloon.
Q Are you the same Allan, Leroy Fal-loon who pled guilty to the crime of larceny in Augusta in July of 1966 ?
“A No, I am not.
“Q Well, are you the same Allan Leroy Falloon, who in May of 1970 pled guilty, or was found guilty of the crime of breaking and entering and larceny in Skowhegan ?
“A I don’t recall it. There was time, yes, but I don’t remember the date. Something like 5, 6 years ago.
“Q You don’t recall, or you don’t recall if you are the same Allan Leroy Fal-loon?
“THE COURT: He has answered specifically he is not.
“WITNESS: I will answer again, I am not.”

The questioning as to claimed prior criminal record was thereupon discontinued. At no time did the State ever offer any evidence that Bagley had in fact been convicted of any crime.

Thus, it is clear that the prosecutor acted improperly. Despite what we said in State v. Toppi, Me., 275 A.2d 805 (1971), and later repeated in State v. Ifill, Me., 343 A.2d 5, 8 (1975), the prosecutor was not

“prepared to establish the fact of conviction by documentary evidence, in the event a negative answer is [was] received to his question.” State v. Toppi, supra, at 812.

*860 Bagley, who was without counsel, made no request for a curative instruction. No curative instruction was given.

During his summation to the jury, the Assistant District Attorney said, as his closing remarks to the jury:

“Consider the fact Mr. Bagley does have a previous record. Consider his credibility. Thank you.”

This statement was never corrected, and the presiding justice gave no curative instruction.

Appellant argues that the State’s attempt to impeach his co-defendant Bagley by proceeding in a manner incompatible with the suggestions we made in State v. Toppi, supra, and State v. I fill, supra, was highly prejudicial. He continues his argument by stating that had his co-defendant been represented by counsel, the “evidence” would have been objected to and excluded by the presiding justice based on the caveat described in Toppi. He claims that since the cases were consolidated, the jury may well have considered the lack of credibility resulting from the alleged past criminal record of his co-defendant in determining appellant’s own guilt.

In State v. Wing, Me., 294 A.2d 418, 420 (1972), we quoted with approval from United States v. Barber, 442 F.2d 517, 529 (3rd Cir. 1971), to the effect that:

“ ‘Generally speaking where several defendants are jointly indicted they should be tried together, particularly where the charges against them arise out of joint acts allegedly committed by each in the presence of each other. In such cases, joint trials are favored in the interest of conserving judicial economy, avoiding duplicitous, time-consuming and expensive trials, conserving public funds, diminishing inconvenience to witnesses and public authorities, and promptly trying those accused of crime.’ ” (Emphasis added.)

However, we did not thereby intend to suggest that joinder should always be had.

In State v. Coty, Me., 229 A.2d 205, 213 (1967), we made it clear that a defendant claiming an order of joinder constituted an abuse of discretion would be required to show that he had been prejudiced thereby.

Clearly, prejudice can result from joinder. Once joinder has occurred the presiding justice must keep a watchful eye that no undue prejudice creeps upon the scene. Schaffer v. United States, 362 U.S. 511, 80 S.Ct. 945, 4 L.Ed.2d 921 (1960); 8 J. Moore, Federal Practice, § 1404[1].

Though the alleged error in the instant case does not involve the same deficiency as that found in Bruton v. United States, 391 U.S. 123, 88 S.Ct. 1620, 20 L.Ed.2d 476 (1968) (right of defendant to confront his accuser), many of the same policy considerations are present. As the Supreme Court recognized,

“the practical and human limitations of the jury system [are such that they] cannot be ignored.” Id., 391 U.S. at 135, 88 S.Ct. at 1627.

The Court quoted with approval the Comments to Rule 14, F.R.Crim.P.:

“An important element of a fair trial is that a jury consider only relevant and competent evidence bearing on the issue of guilt or innocence.” Id., 391 U.S. at 130, n. 6, 88 S.Ct. at 1625.

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366 A.2d 858, 1976 Me. LEXIS 403, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-cuddy-me-1976.