State of Maine v. Bradley Williams

Summary

The Maine Supreme Judicial Court affirmed Bradley Williams’s convictions for two counts of stalking and two counts of harassment. The court rejected challenges concerning trial fairness, evidentiary rulings, motions for judgment of acquittal, amendment of the charging complaint, and omitted jury instructions. The court also addressed ethical concerns regarding an unsupported allegation in appellate counsel’s brief.

Holdings

1. The trial court did not deny Williams a fair trial. Its conduct, viewed in context, did not fatally infect the proceedings or prevent the jury from deciding the facts fairly.
2. The prior protection-from-harassment judgment did not have collateral-estoppel or res judicata effect in the criminal prosecution.
3. The trial court did not commit reversible error by allowing testimony that Williams’s lawsuit against a victim had been dismissed with prejudice.
4. The evidence was sufficient for a rational jury to find each element of harassment proven beyond a reasonable doubt, including that Williams intended to harass both victims through the fliers and the June 3, 2016, letter.
5. The trial court did not abuse its discretion by amending the harassment counts to allege that the course of conduct occurred in Waldo County.
6. The trial court committed no obvious error by declining to instruct the jury on the requested burden-of-proof, protected-speech, actual-malice, and anti-SLAPP issues.
7. The court declined to consider Williams’s ineffective-assistance claims on direct appeal.

Questions Presented

1. Whether the trial court created a prejudicial trial environment that denied Williams a fair trial.
2. Whether a prior protection-from-harassment judgment in Williams’s favor had collateral-estoppel or res judicata effect in the criminal prosecution.
3. Whether the trial court plainly erred by admitting testimony that a civil lawsuit filed by Williams had been dismissed with prejudice.
4. Whether the evidence was sufficient to support the harassment convictions and whether the trial court applied the proper standard in denying the first motion for judgment of acquittal.
5. Whether the trial court abused its discretion by amending the harassment counts to allege that the conduct occurred in Waldo County rather than specifically in Lincolnville.
6. Whether the trial court committed obvious error by failing to give requested jury instructions concerning the State’s burden, protected speech, actual malice, and Maine’s anti-SLAPP statute.
7. Whether Williams’s ineffective-assistance claims could be considered on direct appeal.

Disposition

affirmed