State v. Briggs, 2003 ME 137

Summary

The Maine Supreme Judicial Court held that the trial court improperly imposed a two-year probationary period because the record did not establish beyond a reasonable doubt that the offenses involved domestic violence, limiting probation to one year. The court upheld the batterers' intervention program as a permissible probation condition and declined to review challenges to the propriety, rather than legality, of the imprisonment sentences on direct appeal.

Holdings

1. A two-year probation term for a Class D offense is illegal unless the State proves beyond a reasonable doubt that the crime involved domestic violence. Because the record did not establish that the charged offenses included the required allegation and proof, the two-year probation term had to be vacated.
2. The requirement that Briggs complete a certified batterers' intervention program was not illegal on its face, even though completing the program within a reduced one-year probation period might be difficult.
3. The claims that the maximum prison sentences were improper because of Briggs's limited criminal record or decision to proceed to trial challenged the propriety, rather than the legality, of the sentences and were not reviewable on direct appeal. The concurrent 364-day sentences were statutorily authorized and therefore not illegal.

Questions Presented

1. Whether the Superior Court could impose a two-year probationary period for Class D convictions without proof beyond a reasonable doubt that the crimes involved domestic violence.
2. Whether requiring completion of a certified batterers' intervention program was an illegal condition of probation.
3. Whether the imposition of statutory maximum prison sentences was reviewable on direct appeal because Briggs had a limited criminal record and allegedly declined to plead guilty.

Disposition

reversed_and_remanded