Enough is Enough: The Law Court's Decision to Functionally Raise the "Reasonable Connection" Relevancy Standard in State v. Mitchell

Authors

Robert P. Hayes, University of Maine School of Law

Abstract

In State v. Mitchell, the Maine Supreme Judicial Court, sitting as the Law Court, affirmed a jury verdict finding Thomas Mitchell guilty of a 1983 murder. In doing so, the Law Court examined two issues: First, whether the trial court “abused its discretion in excluding evidence of an alternative suspect”; and second, whether the trial court’s decision to admit evidence stemming from an autopsy performed two decades before the trial violated the Confrontation Clause of the United States Constitution. In reaching the alternative suspect decision, the Law Court held that the evidence proffered by Mitchell did not establish a reasonable connection between the alternative suspect and the crime “sufficient to raise a reasonable doubt” as to Mitchell’s own guilt. In previous decisions, the Law Court noted the dangers and concerns implicated by applying a heightened standard. However, in Mitchell, the majority functionally conflated the “reasonable connection” standard with the direct connection doctrine, where an application of the existing limitations on the admissibility of evidence set forth in the Maine Rules of Evidence would be a more appropriate method for determining the admissibility of alternative suspect evidence.

First Page

531

Recommended Citation

Robert P. Hayes, Enough is Enough: The Law Court's Decision to Functionally Raise the "Reasonable Connection" Relevancy Standard in State v. Mitchell, 63 Me. L. Rev. 531 (2011).
Available at: https://digitalcommons.mainelaw.maine.edu/mlr/vol63/iss2/12