State of Maine v. Joshua T. Williamson

Summary

The Maine Supreme Judicial Court affirmed Joshua T. Williamson’s convictions for operating under the influence and criminal mischief. The court held that the State satisfied the statutory foundation requirements for admitting the Intoxilyzer result and that the late disclosure of an investigation involving a witness did not violate Brady or due process.

Holdings

1. The trial court properly admitted the Intoxilyzer result because the State presented competent evidence satisfying both statutory requirements. The Department's stamp of approval established paragraph H, and the Department chemist's initials on the testing solution constituted a statement of the Department sufficient to satisfy paragraph I.
2. The State did not violate Williamson's due-process rights under Brady because it disclosed the information during the first day of trial, soon after learning of the investigation, and the record did not show that the information was favorable, exculpatory, or impeaching.
3. The unpreserved claims based on M.R.U. Crim. P. 16 and notions of fair play did not constitute obvious error.

Questions Presented

1. Whether the trial court erred by admitting the Intoxilyzer breath-test result when the State allegedly failed to satisfy paragraphs H and I of 29-A M.R.S. § 2431(2).
2. Whether the State's disclosure during trial that a prosecution witness had been investigated for accidentally shooting himself violated Williamson's due-process rights under Brady v. Maryland.
3. Whether the late disclosure violated M.R.U. Crim. P. 16 or notions of fair play under the state and federal constitutions under the obvious-error standard.

Disposition

affirmed