State of Maine v. Christopher Murray

Summary

The Maine Supreme Judicial Court affirmed Christopher Murray’s convictions for intentional or knowing murder, elevated aggravated assault, and robbery. The court held that the evidence did not generate a jury instruction on duress and that the trial court properly excluded an expert’s opinion that the surviving victim was more likely than not confabulating her memories. The court also affirmed the sentences, including life imprisonment for murder.

Holdings

1. The trial court properly refused to instruct the jury on duress because, even viewing the evidence in the light most favorable to Murray, there was no evidence that Tony made a direct threat to Murray, that Murray heard any threat to Alexis, or that Murray was compelled by a threat of imminent death or serious bodily injury or by force.
2. The trial court did not abuse its discretion by excluding the expert's opinion that it was more likely than not that Diem was confabulating her memory because the opinion impermissibly addressed witness credibility and an ultimate factual issue, was not based on a scientific evaluation of Diem's specific injury, and would not have assisted the jury.

Questions Presented

1. Whether the evidence generated a jury instruction on the defense of duress for Murray's charged offenses, including accomplice liability murder.
2. Whether the trial court abused its discretion by excluding the psychological expert's opinion that it was more likely than not that Diem was confabulating her memory of the shootings.
3. Whether the sentencing court's imposition of a life sentence violated Murray's Sixth Amendment right to a jury determination of a Shortsleeves factor.

Disposition

affirmed