State v. Weidul

628 A.2d 135, 1993 Me. LEXIS 126
CourtSupreme Judicial Court of Maine
DecidedJuly 13, 1993
StatusPublished
Cited by11 cases

This text of 628 A.2d 135 (State v. Weidul) 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. Weidul, 628 A.2d 135, 1993 Me. LEXIS 126 (Me. 1993).

Opinions

RUDMAN, Justice.

Ernest Brian Weidul appeals from a Superior Court (York County, Cole, J.) judgment entered on a jury verdict convicting him of criminally threatening his father with a dangerous weapon, 17-A M.R.S.A. § 209 (1983). For the first time, on appeal, Weidul argues that the trial court fatally departed from the instructions that a trial court is authorized to give to a jury after it has commenced to deliberate. We are once again faced with the task of evaluating the effect of a departure from the ABA Standards for Criminal Justice § 15-4.4 (1980). Because we conclude that the trial court’s departure from the ABA standard presents an unacceptable risk of an unfair trial, we vacate the judgment of the Superior Court.

[136]*136In 1972, we “concluded” that the time had come for Maine courts to abandon the use of the Tuey-Allen1 charge or any modified version thereof. State v. White, 285 A.2d 832, 838 (Me.1972). Because the Tuey-Allen charge is coercive and invades the province of the jury, we recommended against the use of the charge or any modified form thereof after the jury commenced to deliberate in any criminal case. Id. at 838. In its place, we adopted the ABA’s standard that reads:

Standard 15-4.4. Length of deliberations; deadlocked jury
(a) Before the jury retires for deliberation, the court may give an instruction which informs the jury:
(i) that in order to return a verdict, each juror must agree thereto:
(ii) that jurors have a duty to consult with one another and to deliberate with a view to reaching an agreement, if it can be done without violence to individual judgment;
(iii) that each juror must decide the case for himself or herself but only after an impartial consideration of the evidence with the other jurors;
(iv) that in the course of deliberations, a juror should not hesitate to reexamine his or her own views and change an opinion if the juror is con- - vinced it is erroneous; and
(v) that no juror should surrender his or her honest conviction as to the weight or effect of the evidence solely because of the opinion of the other jurors, or for the mere purpose of returning a verdict.
(b) If it appears to the court that the jury has been unable to agree, the court may require the jury to continue their deliberations and may give or repeat an instruction as provided in paragraph (a). The court shall not require or threaten to require the jury to deliberate for an unreasonable length of time or for unreasonable intervals.
(c) The jury may be discharged without having agreed upon a verdict if it appears that there is no reasonable probability of agreement.

ABA Standards for Criminal Justice § 15-4.4 (1980).

Due to repeated departures from the ABA standard we have had to revisit this issue over the years. See e.g. State v. Heald, 292 A.2d 200 (Me.1972) (reaffirming recommendations in White at 204); Gould v. Bangor and Aroostook R.R. Co., 292 A.2d 837 (Me.1972) (admonition in White applies to civil as well as criminal trials); State v. Quint, 448 A.2d 1353, 1357 (Me. 1982) (“recommending” use of ABA standard); State v. Rusher, 468 A.2d 1008, 1010 (Me.1983) (noting our previous “strong” recommendations that ABA standards be utilized); State v. Cote, 507 A.2d 584, 586 (Me.1986) (urging “strict adherence” to ABA standard). Our use of progressively stronger language has failed to sufficiently dissuade departures from, or modifications to, the ABA standard. An erroneous instruction to a potentially deadlocked jury cuts to the heart of the criminal process and any convictions secured following such instructions are highly suspect. A departure from the ABA standard requires us to determine whether the modified charge equates to the ABA standard, and forces us to determine the effect the charge had on the deadlocked jury. “No benefits from deviations from [the ABA standard] can justify imposing [on] this Court the difficult task of weighing the coercive impact of such variations in particular circumstances.” Cote, 507 A.2d at 586 (quotations omitted). Accordingly, we announce that departures from the ABA standard, if the subject of a proper objection, will be met by this court with summary reversal. This rule will serve to ensure defendants a fair trial and conserve judicial resources.

A review of the trial court’s charge in the instant case reveals that the charge violated several of the principles embodied in the ABA standard and skewed the carefully wrought balance that would have been achieved if the ABA standard had been strictly followed. Since no objection [137]*137was raised to the trial justice’s language departing from the ABA standard, we review to determine “whether the offending instruction ‘when reviewed with the charge as a whole constituted highly prejudicial error tending to produce manifest injustice.’ ” See State v. Quint, 448 A.2d 1353, 1355 (Me.1982) (quoting State v. Mahaney, 437 A.2d 613, 618-19 (Me.1981)).

We agree with Weidul that the court’s instructions were erroneous in the following particulars:

1) The court’s instructions failed to strike the crucial balance between the competing considerations of the desirability of a juror’s reconsideration of his opinions in order to reach a verdict and the need that any verdict rendered accurately reflect honestly held beliefs, see State v. Cote, 507 A.2d 584, 586 (Me. 1986);
2) The charge repeatedly emphasized the desirability of reaching a verdict while failing to properly note the countervailing, but no less important, requirement that an individual juror maintain his or her well-reasoned beliefs regardless of its effect on the ability of the jury to render a unanimous verdict, of. ABA Standards for Criminal Justice § 15-4.4. (1980);
3) The instructions incorrectly and improperly suggested that the jurors would have to deliberate until they returned verdicts, and that there was no other alternative, see id.;
4) The court’s statements to the effect that “there are only two possible verdicts here” are virtually indistinguishable from the instruction that “[y]ou have got to reach a decision in this case,” that was condemned in Jenkins v. United States, 380 U.S. 445, 446 [85 S.Ct. 1059, 1060, 13 L.Ed.2d 957] (1965) (per curiam).

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State v. Weidul
628 A.2d 135 (Supreme Judicial Court of Maine, 1993)

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Bluebook (online)
628 A.2d 135, 1993 Me. LEXIS 126, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-weidul-me-1993.