State of Maine v. Daudoit Butsitsi

Summary

The Maine Supreme Judicial Court affirmed Daudoit Butsitsi’s thirty-eight-year sentence for intentional or knowing murder. The court held that, under obvious-error review, the sentencing judge’s references to Butsitsi’s national origin, cultural background, and community did not create an appearance of racial bias or demonstrate that the sentence was based on race or national origin. The court also declined to adopt de novo review for unpreserved claims of judicial bias at sentencing.

Holdings

1. An unpreserved claim that sentencing remarks reflected judicial bias is reviewed for obvious error, including when the alleged bias concerns the defendant's national origin.
2. The sentencing court did not violate due process or create an appearance of racial bias by considering the defendant's cultural background, exposure to violence, and community circumstances in context. The sentence was not shown to have been based on the defendant's race or national origin.

Questions Presented

1. What standard of review applies to an unpreserved claim that sentencing remarks created an appearance of judicial bias based on the defendant's national origin?
2. Whether the sentencing court violated due process by imposing a sentence illegally based on the defendant's race or national origin or by making remarks that created an appearance of racial bias.

Disposition

affirmed