Summary
The Maine Supreme Judicial Court affirmed the murder and kidnapping convictions of David Lakin and Shaun Tuttle following their joint jury trial. The court held that mutually antagonistic defenses, without a specific showing of prejudice such as a Bruton confrontation violation, did not require severance under Maine Rule of Criminal Procedure 8(d).
Holdings
- Mutually antagonistic defenses are not prejudicial per se and do not, standing alone, require severance of a joint trial.
- The Superior Court did not abuse its discretion in denying severance because the State excluded the defendants' inculpatory statements, the defendants showed no specific prejudice, and the jury was instructed to consider the evidence against each defendant separately.
Questions Presented
- Whether the Superior Court abused its discretion by denying the defendants' motions to sever their joint trial.
- Whether mutually antagonistic defenses, in which each codefendant accused the other of the killing, created prejudice requiring severance as a matter of law.
Disposition
affirmed
Cases Cited (8)
- State v. Turner, 2001 ME 44, 766 A.2d 1025(followed)
- State v. Parsons, 2005 ME 69, 874 A.2d 875(followed)
- Bruton v. United States, 391 U.S. 123, 88 S. Ct. 1620, 20 L. Ed. 2d 476 (1968)(distinguished)
- State v. Boucher, 1998 ME 209, 718 A.2d 1092(followed)
- Zafiro v. United States, 506 U.S. 534, 113 S. Ct. 933, 122 L. Ed. 2d 317 (1993)(followed)
- State v. Chesnel, 1999 ME 120, 734 A.2d 1131(followed)
- State v. Lakin, No. SRP-05-411 (Me. Sent. Rev. Panel, Dec. 19, 2005)(not analyzed)
- State v. Tuttle, No. SRP-05-387 (Me. Sent. Rev. Panel, Dec. 19, 2005)(not analyzed)
Cited In (0)
No citing cases on record yet.
Court Document
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