State v. Mills, 2006 ME 134

Summary

The Maine Supreme Judicial Court affirmed Brandon Mills's convictions for manslaughter and burglary. The court held that the trial court properly excluded a witness's remote juvenile adjudication and Department records concerning prior knife possession because the proposed evidence was irrelevant and too speculative to support an alternative-perpetrator theory.

Holdings

1. The trial court properly excluded the evidence because Mills presented no evidence linking Garcia's remote history of possessing knives to the stabbing, making the proposed alternative-perpetrator theory speculative and the evidence irrelevant.
2. The exclusion of the challenged evidence did not violate Mills's confrontation rights because the evidence was irrelevant and speculative; the court did not need to decide Mills's broader constitutional challenge concerning the scope of Davis v. Alaska.
3. The Department records were properly excluded because Mills sought to use Garcia's prior knife possession to suggest that she possessed a knife and acted similarly at the time of the stabbing, which was prohibited propensity reasoning under M.R. Evid. 404(b), and the records were independently irrelevant.

Questions Presented

1. Whether the trial court abused its discretion or committed clear error by excluding evidence of Isabel Garcia's juvenile adjudication for carrying a concealed weapon and Department records concerning her past possession of knives.
2. Whether exclusion of that evidence violated Mills's Sixth Amendment right to confront and cross-examine Garcia.

Disposition

affirmed