State of Maine v. Daniel Cardona

Summary

The Maine Supreme Judicial Court affirmed Daniel Cardona’s conviction for unlawful sexual contact. The court held that the trial court acted within its discretion in admitting evidence of Cardona’s subsequent sexual behavior toward the victim under Maine Rule of Evidence 403. It also held that evidence of threats Cardona made toward the victim’s cousin was properly excluded as irrelevant because there was no sufficient connection to the victim’s allegations or motive to fabricate.

Holdings

1. The court did not abuse its discretion in admitting the evidence of the sex-toy incident, as the evidence was relevant from inception and the trial court's initial Rule 403 ruling was not final.
2. The trial court did not err in excluding the threat evidence as irrelevant because there was no evidence the victim knew of the threats or that the victim and family conspired to fabricate the allegations.

Questions Presented

1. Whether the trial court abused its discretion in admitting evidence of Cardona's subsequent sexual behavior toward the victim under M.R. Evid. 403.
2. Whether the trial court erred in excluding evidence of Cardona's threats toward the victim's cousin as irrelevant.

Disposition

affirmed