State of Maine v. Jacob Miller

Summary

The Maine Supreme Judicial Court affirmed Jacob Miller’s conviction and sentence for domestic violence aggravated assault. The court held that due process permitted the sentencing court to rely on the victim’s unsworn statements and a medical expert’s report because Miller had an opportunity to challenge the information but did not do so. The court reviewed the unpreserved claims for obvious error and found none.

Holdings

1. A sentencing court may rely on unsworn victim statements when the defendant was given an opportunity to contest, deny, explain, or cross-examine the information and declined to do so, provided the information is factually reliable and relevant.
2. A sentencing court may consider an expert medical report without requiring live testimony or cross-examination when the defendant had the report before sentencing, failed to challenge it or request cross-examination or a continuance, and the report's contents and corroborating materials support its reliability.
3. The court declined to reach Miller's Sixth Amendment Confrontation Clause argument because it was inadequately developed.

Questions Presented

1. Whether due process prohibited the sentencing court from relying on the victim's unsworn statements describing additional strangulation incidents when Miller did not object, request an oath or cross-examination, or present an alternative account.
2. Whether due process prohibited the sentencing court from relying on the State's expert medical report when the report's author was not subject to cross-examination.
3. Whether the sentencing court committed obvious error in determining the basic sentence by relying on information that was inaccurate, unreliable, or insufficiently tested.

Disposition

affirmed