Summary
Michael R. Laferriere appealed his conviction for assault against a family or household member, arguing that the trial court improperly excluded evidence of the victim's prior violent acts. The Maine Supreme Judicial Court held that such evidence was relevant to the reasonableness of his asserted self-defense and defense-of-property claims, vacated the conviction, and remanded for a new trial.
Topics
Practice areas
Questions Presented
- Whether the trial court abused its discretion by excluding evidence of prior violent acts allegedly committed by the victim when Laferriere asserted self-defense and defense of property.
- Whether exclusion of the evidence was harmless.
Holdings
- When a defendant raises self-defense or defense of property, evidence of the victim's reputation for violence, or prior violent acts allegedly known to the defendant before the event, may be admissible to show the defendant's reasonable apprehension of immediate danger; therefore, the trial court abused its discretion by categorically excluding Laferriere's proffered evidence.
- The erroneous exclusion of the evidence was not harmless because it was not highly probable that the error did not affect the outcome of the bench trial.
Key quotations
“when an accused raises the defenses of self-defense or defense of property, “this rule does not keep out the victim’s reputation for violence, proved to have been known to the accused before the event, for the purpose of showing his reasonable apprehension of immediate danger.”” (¶ 4)
Factual background
Laferriere and the victim engaged in a physical altercation in their shared residence, resulting in injuries to the victim. The victim initially told a responding deputy that Laferriere initiated the confrontation, but at trial testified that Laferriere struck her only after she attacked his property with a large knife. Laferriere testified that the victim initiated the confrontation and that he used force in defense of himself and his property. He sought to testify about prior violent acts allegedly committed by the victim to show the reasonableness of his fear of imminent harm, but the trial court excluded the evidence.
Procedural history
The District Court in Ellsworth sustained the State's objection to evidence concerning prior violent acts allegedly committed by the victim against Laferriere, convicted Laferriere after a bench trial, and entered judgment. The Supreme Judicial Court of Maine vacated the conviction and remanded for a new trial.
Remand instructions
The judgment of conviction was vacated, and the case was remanded to the District Court for further proceedings consistent with the opinion, including a new trial.