Sullivan v. State of Maine

CourtSuperior Court of Maine
DecidedJanuary 27, 2020
DocketAROcr-19-128
StatusUnpublished

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

Bluebook
Sullivan v. State of Maine, (Me. Super. Ct. 2020).

Opinion

STATE OF MAINE SUPERIOR COURT AROOSTOOK, ss DOCK.ET NO. AROCD-CR-19-128

DAVID SULLIVAN ) Petitioner ) ) ) ) vs ) DECISION ) ) ) STATE OF MAINE ) Respondent )

BACKGROUND

Pending before the court is David Sullivan's Petition for Post-Conviction Relief. By an

Indictment dated March 6, 2014, Sullivan was charged with the following: Count 1- Unlawful

Possession of Scheduled Drugs, 17-A, MRSA §1107-A(l)(B)(3), Class C; Count 2- Unlawful

Possession of Scheduled Drugs, 17-AMRSA §1107-A(l)(B)(4), Class C; Count3- Unlawful

Trafficking of Scheduled Drugs, 17-A MRSA §1103(1-A)(A), Class B; and Count 4-Aggravated

Trafficking in Scheduled Drugs, 17-A MRSA §1105-A(l )(I), Class A. However, Count 3 and

Count 4 were actually the same charge, Count 4 being the elevated offense based upon volume.

Trial was held on January 23 through January 25, 2017. Counts 1, 2 and 3 were presented to the

jury, and as for Count 4, the jury was presented a single interrogatory asking the jury to

determine whether the trafficking involved 300 or more pills. On January 25, 2017 the jury

returned a verdict of guilty on all charges, and found with the trafficking charge more than 300

pills had been involved. On February 10, 2017 Sullivan was sentenced to 12 years, with all but 4

years suspended on Count 4, with concurrent sentences of 1 year on Counts 1 and 2; Count 3 was (

As to the first prong of the test, counsel's representation falls below the objective standard of

reasonableness if it falls below what might be expected from an ordinary fallible attorney.

Philbrook, ,r 7. Judicial inquiry into the effectiveness is highly deferential, and the post­

conviction court must make every effort to eliminate the distorting effects of hindsight. Id

In Roberts v. State of Maine, 2014 ME 125, if23,I03 A.3d 1031,1039, the Law Court indicated

that in order to prove that counsel's performance was constitutionally deficient,

"a defendant must show that counsel's representation fell below an objective standard of reasonableness. The question is whether the counsel's performance fell within the wide range of reasonable professional assistance that a competent criminal defense counsel could provide under prevailing professional norms. The Strickland test compels us to reconstruct the circumstances of counsel's challenged conduct and to evaluate the conduct from counsel's perspective at the time." (Internal citations and punctuation omitted.)

As to the second prong, whether prejudice is established, a petitioner must prove that there is a

reasonable probability that, but for counsel's unprofessional errors, the result of the proceeding

would have been different, meaning that the ineffective assistance of counsel rose to the level of

compromising the reliability of the conviction and undermining confidence in it. Philbrook, ,r 8;

citing Theriault v. State, 2015 ME 137, ,r,r 19, 25. A conviction may be unreliable and not

worthy of confidence, thus satisfying the "reasonable probability" test, even without proof that a

different outcome was "more likely than not", as the now superseded "outcome determinative"

test would require. Id The "reasonable probability" test is different from an "outcome­

determinative" standard, which is the quantitative inquiry that would require proof "that

counsel's deficient conduct more likely than not altered the outcome in the case." Theriault, ,r20.

Rather, the court's analysis must be qualitative in nature-that is to determine whether the

petitioner has demonstrated that trial counsel's performance undermines confidence in the

3 ( (

outcome of the case and renders that outcome unreliable. Theriault, if 19. "..the result of a

proceeding can be rendered unreliable, and hence the proceeding itself unfair, even if the errors

of counsel cannot be shown by a preponderance of the evidence to have determined the

outcome." Theriault, ,r20, citing Strickland, 466 U.S., at 694.

DISCUSSION

1. Outcome oftrial, including choosing not to plead, to proceed to trial, and not to testify.

The primary argument made by Sullivan is his attorney failed to recognize he is intellectually

impaired and of questionable competence. And Sullivan alleges a consequence of his impaired

intellect and questionable competence was he was unable to appreciate the risk of going to trial

or benefits of plea bargaining. Sullivan also alleges his attorney failed to properly advise him of

his right to testify. Finally, Sullivan argues his attorney failed at sentencing to advocate that these

impairments be considered by the court in rendering a sentence. 1

The court agrees that the testimony of Dr. Logue and her report presents Sullivan as a defendant

with cognitive limitations. He dropped-out of school after the 9th grade and never obtained a

GED. Sullivan's scores in the neuropsychological testing performed by Dr. Logue, which tested

his intellectual functioning, comprehension, memory, and executive function, indicate he is in

the low to borderline impaired level, and has the reading level of a second grader. And Dr. Logue

testified Sullivan has poor complex reasoning skills which would make it difficult for him to

grasp complex legal concepts and how they apply to him. Based on those assessments, Dr. Logue

opines Sullivan did not appreciate the benefits of plea bargaining with his case. For example, Dr.

1 Advocacy at sentencing will be addressed in section 2.

4 (

Logue testified Sullivan could not grasp the concept of plea bargaining his case to get less time

in jail because he was not in jail at the time. She also accepted Sullivan's statements to her that if

he took a plea offer he would be sentenced to one year in jail.

On the other hand, Dr. Logue testified Sullivan had a basic understanding of the charges, that he

would go to jail if found guilty, and knew generally what plea bargaining was. And she indicated

his emotions played a large role in how he communicated. However, Dr. Logue also

acknowledged that Sullivan always maintained his innocence, and had very strong opinions

about both his innocence and distrust of police and lawyers.

It is the court's sense that some level of Dr. Logue's opinion of Sullivan's failure to appreciate

the benefits of plea bargaining arises from her belief that he should have recognized the State's

case was strong and a plea bargain would reduce have reduced his jail time. But what is also just

as possible is Sullivan simply had strong views about his innocence. In fact at the hearing,

Sullivan testified that under no scenario would he have pleaded guilty, and he told this to his

lawyer. This is consistent with Dr. Logue's testimony that at her interview of Sullivan, he never

acknowledged guilt and always maintained his innocence.

The court also notes that Dr. Logue's suggestion that Sullivan never understood the plea bargain

process seems to be based, at least in part, in her view that the State's case was strong. This was

a belief she had without reviewing the police reports. At the same time, Dr. Logue testified that

she agreed Sullivan was an individual with strong opinions and not easily swayed. The court

feels that Dr. Logue's opinions fail to adequately account for the possibililty that Sullivan was

5 ( (

not interested in a plea bargain for the basic reason he simply believed he would not be found

guilty.

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Related

Manuel Gonz Lez-Soberal v. United States
244 F.3d 273 (First Circuit, 2001)
Mark J. Theriault v. State of Maine
2015 ME 137 (Supreme Judicial Court of Maine, 2015)

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