State v. Connors

GLASSMAN, Justice,

dissenting.

Because I do not agree with the Court that the evidence relating to the Waterboro burglary was properly admitted, I respectfully dissent. It is well established that to be relevant pursuant to M.R.Evid. 402, and not excluded pursuant to M.R.Evid. 408, the proffered “signature” evidence must be “sufficiently idiosyncratic” to support the reasonableness of an inference that both offenses were committed by the same person. State v. Joubert, 603 A.2d 861, 866 (Me.1992); M.R.Evid. 404(b). It is also well established that evidence that the defendant committed the same offense, although unrelated in time and place, is “extremely prejudicial.” State v. Works, 537 A.2d 221, 223 (Me.1988); M.R.Evid. 403.1 The Court today has failed to give adequate consideration to either of these principles.

The eases relied on by the Court to illustrate the admissibility of the challenged evidence do not support its admission. In Jou-bert, the defendant, charged with the murder of 11-year-old Ricky Stetson, on a plea of guilty had been convicted previously in Nebraska of the murder of Danny Joe Eberle. Over the objection of Joubert, a Nebraska journalist testified that Joubert had told him that, during an encounter with Eberle, he had bitten Eberle in several places and had used a knife to try to hide the bite mark on Eberle’s left thigh by cutting or carving it. The State carefully avoided eliciting any testimony that Eberle had been killed or that Joubert had been convicted of his murder. The trial court had before it a stipulation of the parties detailing the striking similarities in the Maine and Nebraska crimes: both victims were white males of about the same age and height; both were killed by knife wounds; both were bitten on the leg “and had crisscross slash wounds that attempted to disguise the bite marks”; both victims had been on foot prior to their respective attacks; both had been bound; and the bodies of both had been left at the murder sites. Joubert, 603 A.2d at 866. We upheld the challenged evidence, stating that “[t]he unusual bite marks with concomitant slashes, together with the similar physical characteristics and manner of death of both victims, ‘are sufficiently idiosyncratic’ to support the reasonableness of the trial court’s inference that they were killed by the same person” and the evidence was not so unfairly prejudicial as to outweigh its probative value. Id. Similarly, in State v. Webber, 613 A.2d 375 (Me.1992), we determined that evidence was sufficiently idiosyncratic when, on two separate occasions, the defendant vandalized the same victim’s car, in the same parking lot, at the same time of day and by scratching the word “AIDS” into the vehicle’s paint with a sharp implement. Id. at376.2

Here, by contrast, nothing in the manner in which these burglaries were accomplished is idiosyncratic. In support of its decision, the Court recites the only similarities between the two offenses: “At both crime scenes, wires were cut and alarms disengaged, safes man-handled, and bootprints left.” The Court correctly points out that the bootprints lacked any identifying characteristics, leaving only the fact that the perpetrators cut the telephone lines, disengaged the alarms and attempted to gain access to the respective safes. It is difficult to imagine, in the context of the burglary of a commercial establishment, a set of characteristics less helpful in ascertaining the identity of the perpetrator.

In addition, the State’s argument that the evidence was offered to corroborate the testimony of Jeffrey Roderick, Connors’s cellmate, is equally meritless. The State cannot now seriously contend that, having improperly elicited from Roderick the testimony regarding the Waterboro burglary, the addi*1077tional evidence regarding that burglary was necessary to corroborate Roderick’s testimony.

Notwithstanding the failure to justify the admission of the evidence on signature or credibility grounds, the Court also fails to give adequate consideration to the level of prejudice to the defendant by the submission to the jury of the challenged evidence. In Works, the defendant was charged with assault and public indecency because, while in a supermarket, he exposed his genitals to an eight-year-old girl and “pressed up against her while so exposed.” Works, 537 A.2d at 222. The defendant admitted being present in the supermarket, but denied that he had exposed himself. On cross-examination, the defendant admitted that, at another time subsequent to his indictment in the case at bar, he had masturbated in an aisle of a department store. Id. We held that this evidence, even though of a similar act, was inadmissible as a matter of law pursuant to a Rule 408 analysis and vacated the judgments of conviction. Our reasoning in Works is particularly apt here:

Evidence that defendant had been involved in an incident similar to the offense for which he is on trial is extremely prejudicial. See State v. Goodrich, 432 A.2d 413, 417-18 (Me.1981). The jury is improperly led to believe that if defendant acted in a certain manner once, he probably committed the similar crime charged. Id. The evidence is particularly prejudicial in this case where defendant, although he admitted to being in the supermarket at the time of the crime, has denied that he committed the crime.... Testimony elicited from defendant himself that he had acted similarly at an unrelated time was so highly prejudicial ... that its erroneous receipt in evidence during trial could not be cured by the court’s much later instruction to the jury to disregard it.

Id. at 223.

In my opinion, an application of these well-established governing principles requires that the judgments be vacated.

. M.R.Evid. 403 provides in pertinent part:

Although relevant, evidence may be excluded if its probative value is substantially outweighed by the danger of unfair prejudice_

. Our opinion in State v. Webber, 613 A.2d 375 (Me.1992), notes only that the second vandalism was accomplished in “a manner strikingly similar to the previous vandalism of [the] vehicle.” Id. at 376. The record in Webber, however, discloses the factual similarities noted herein.