State of Maine v. Jeffrey A. Witham Jr.
CourtSupreme Judicial Court of Maine
Date FiledJuly 30, 2026
DocketHan-23-421
JudgeSTANFILL, C.J., and MEAD, CONNORS, LAWRENCE, and DOUGLAS, JJ. *
StatusPublished
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Full Opinion
MAINE SUPREME JUDICIAL COURT Reporter of Decisions
Decision: 2026 ME 75
Docket: Han-23-421
Argued: September 11, 2024
Decided: July 30, 2026
Panel: STANFILL, C.J., and MEAD, CONNORS, LAWRENCE, and DOUGLAS, JJ. *
STATE OF MAINE
v.
JEFFERY A. WITHAM JR.
LAWRENCE, J.
[¶1] Jeffery A. Witham Jr. appeals from judgments of conviction entered
by the trial court (Hancock County, Larson, J.) in two separate matters. In one
matter, Witham was convicted following a jury trial of ten counts, with a lead
count of domestic violence aggravated assault with a dangerous weapon
(Class A), 17-A M.R.S. § 208-D(1)(D) (2020). 1 In the other matter, Witham
entered a conditional guilty plea to one count of tampering with a witness
(Class B), 17-A M.R.S. § 454(1-B)(A)(2) (2026). The court sentenced Witham
to concurrent terms totaling twenty-four years of incarceration, with all but
twenty-two years suspended, and six years of probation. Witham contends that
* Although Justice Horton participated in the appeal, he retired before this opinion was certified.
1This statute has since been amended but not in any way that affects this appeal. See, e.g., P.L.
2023, ch. 465, § 4 (effective Oct. 25, 2023) (codified at 17-A M.R.S. § 208-D(1)(D) (2026)).
2
• the court erred as a matter of law in a third, unrelated criminal
matter when it twice denied him an evidentiary hearing to litigate
whether $24,719 of his funds seized were sufficiently connected to
the criminal offense charged in that matter, and specifically that the
court violated his Sixth and Fourteenth Amendment rights to
counsel of his choosing and due process by violating 15 M.R.S.
§ 5828(1)(E)(1) (2026), which requires a court to order the return
of invalidly-seized assets;
• the trial court erred by not giving a specific-unanimity jury
instruction and by denying his post-judgment motion for a
mental-condition examination; and
• the sentencing court unlawfully increased his sentence based on
o a conclusion that there were firearms involved in the
convicted offenses, despite the jury finding that none of the
offenses were committed with the use of a firearm;
o the consideration of Witham’s age at the time of the offense;
and
o its assessment that Witham had not accepted responsibility
for his conduct.
[¶2] We also conclude that we do not have jurisdiction over the motions
regarding the seized funds because the forfeiture occurred in a matter not
related to the present appeal, and we therefore do not reach the merits of the
forfeiture argument. We conclude that
• no specific-unanimity instruction was needed on Counts 1, 2, 5, 8,
11, 13, and 15;
• the court did not err by denying Witham’s post-judgment motion
for a mental-condition examination;
3
• the court did not err by concluding at sentencing that there were
firearms involved in the convicted offenses, by considering
Witham’s age at the time of the offense for sentencing purposes, or
by considering Witham’s lack of acceptance of responsibility as an
aggravating factor; and
• Counts 1 and 6 should have been merged and Counts 5 and 11 also
should have been merged. See infra ¶¶ 28, 39.
Therefore, we affirm the judgment of conviction but vacate the sentence as to
Counts 1, 5, 6, and 11 and remand the matter for resentencing following merger
of those counts as noted.
I. BACKGROUND
A. Domestic-Violence Case
[¶3] We first describe the case involving the charges of domestic
violence. Viewing the evidence in the light most favorable to the State, the trial
record supports the following facts. State v. Hanscom, 2016 ME 184, ¶ 3, 152
A.3d 632.
[¶4] In June 2020, Witham was living with the victim and the victim’s
six-year-old child in Witham’s home in Hancock County. Witham and the victim
had been in a romantic relationship for around four years. On the morning of
June 24, 2020, Witham’s dog ran away from the home, and Witham became
angry and yelled at the victim. Witham was also angry that the victim had not
4
completed a loan application and that the victim’s child had told someone that
Witham’s dog bit the child. Witham told the victim to leave but before she could
do so, he assaulted her numerous times.
[¶5] Witham assaulted the victim by throwing her against a bureau and
bashing her head on a mirror; strangling her approximately four times, twice
while she was holding the child; jamming a baseball bat against the victim’s
neck; punching the victim in the face with a closed fist; and smashing a calamine
lotion bottle into the victim’s forehead with such force that the words “open”
and “close” were imprinted on her skin. Prior to these events, Witham had hit
the victim once before.
[¶6] In a matter with docket number HANCD-CR-2020-618, Witham was
charged by indictment on June 25, 2020, with eighteen criminal offenses:
• Count 1: Kidnapping with a dangerous weapon (Class A), 17-A M.R.S.
§ 301(1)(A)(4) (2020);2 17-A M.R.S. § 1604(3) (2026); 17-A M.R.S.
§ 1604(5)(A)-(B) (2020), 3 against the victim, having been previously
convicted of domestic violence criminal threatening in two prior cases
and domestic violence assault in one prior case;
• Count 2: Kidnapping (Class A), 17-A M.R.S. §§ 301(1)(A)(4), 1604(5)(B),
against the victim’s child, having the same prior convictions;
2This statute has since been amended but not in any way that affects this appeal. See P.L. 2021,
ch. 299, § B-1 (effective Oct. 18, 2021) (codified at 17-A M.R.S. § 301(1)(A)(4) (2026)).
3 Section 1604(5)(B) has since been amended but not in any way that affects this appeal. See, e.g.,
P.L. 2023, ch. 557, § 4 (effective Aug. 9, 2024) (codified at 17-A M.R.S. § 1604(5)(B) (2026)).
5
• Counts 3 & 4: Kidnapping with a dangerous weapon (Class A), 17-A M.R.S.
§§ 301(1)(A)(4), 1604(3), (5)(A)-(B), against the victim and the victim’s
child respectively, having the same prior convictions;
• Count 5: Domestic violence aggravated assault (Class A), 17-A M.R.S.
§§ 208-D(1)(D), 1604(5)(B), against the victim, having the same prior
convictions;
• Counts 6 & 7: Criminal restraint with a dangerous weapon (Classes B
& A), 17-A M.R.S. § 302(1)(B)(1), (2) (2026); 17-A M.R.S. § 1604(3),
(5)(A)-(B), against the victim and the victim’s child respectively, having
the same prior convictions;
• Count 8: Domestic violence criminal threatening with a dangerous
weapon (Class B), 17-A M.R.S. § 209-A(1)(B)(1) (2020);4 17-A M.R.S.
§ 1604(5)(A) against the victim, having the same prior convictions;
• Counts 9 & 10: Domestic violence terrorizing with a dangerous weapon
(Class B), 17-A M.R.S. § 210-B(1)(B)(1) (2020); 5 17-A M.R.S.
§§ 1604(5)(A), having the same prior convictions;
• Counts 11 & 12: Domestic violence assault (Class C), 17-A M.R.S.
§ 207-A(1)(B)(1) (2020),6 against the victim and the victim’s child
respectively, having the same prior convictions;
• Count 13: Possession of a firearm by a prohibited person (Class C),
15 M.R.S. § 393(1)(A-1)(1) (2020), 7 having the same prior convictions;
4 This statute has since been amended but not in any way that affects this appeal. See, e.g.,
P.L. 2023, ch. 465, § 8 (effective Oct. 25, 2023) (codified at 17-A M.R.S. § 209-A(1)(B)(1) (2026)).
5 This statute has since been amended but not in any way that affects this appeal. See, e.g.,
P.L. 2023, ch. 465, § 10 (effective Oct. 25, 2023) (codified at 17-A M.R.S. § 210-B(1)(B)(1) (2026)).
6 This statute has since been amended but not in any way that affects this appeal. See, e.g.,
P.L. 2023, ch. 465, §§ 2, 3 (effective Oct. 25, 2023) (codified at 17-A M.R.S. § 207-A(1)(B)(1) (2026)).
7 This statute has since been amended but not in any way that affects this appeal. See P.L. 2023,
ch. 491, § 1 (effective Aug. 9, 2024) (codified at 15 M.R.S. § 393(1)(A-1)(1) (2026)). Witham
stipulated that he was a “prohibited person” who was not allowed to possess firearms pursuant to
15 M.R.S. § 393(1)(A-1)(1).
6
• Count 14: Criminal simulation (Class C), 17-A M.R.S. § 705(1)(E)(2)
(2026);
• Count 15: Endangering the welfare of a child with the use of a dangerous
weapon (Class C), 17-A M.R.S. § 554(1)(C) (2026); 17-A M.R.S.
§§ 1604(3), (5)(A), against the victim’s child;
• Count 16: Obstructing report of crime or injury (Class D), 17-A M.R.S.
§ 758(1)(A) (2026);
• Count 17: Criminal mischief (Class D), 17-A M.R.S. § 806(1)(A) (2026);
and
• Count 18: Violation of condition of release (Class E), 15 M.R.S.
§ 1092(1)(A) (2026).
[¶7] On January 13, 2023, despite being represented by counsel, Witham
personally wrote a letter to the court titled “Motion for Dismissal,” asserting
that his due process rights and right to counsel had been violated because “the
government seiz[ed] $24,719”8 that he needed to pay for an attorney of his
8 Witham’s funds were seized in a separate case, docket number HANCD-CR-2022-00196,
unrelated to the cases subject to this appeal, in which the grand jury indicted Witham with three
counts of trafficking in scheduled drugs (Classes A and B), 17-A M.R.S. §§ 1103, 1105-A (2022); and
two counts of criminal forfeiture, 15 M.R.S. § 5826 (2022). Title 17-A M.R.S. § 1103 has since been
amended but not in any way that affects this appeal. See P.L. 2025, ch. 173 § 4 (effective Sep. 24,
2025) (codified at 17-A M.R.S. § 1103 (2026)). Title 17-A M.R.S. § 1105-A has since been amended
but not in any way that affects this appeal. See P.L. 2025, ch. 173, § 6 (effective Sep. 25, 2025)
(codified at 17-A M.R.S. § 1105-A (2026)). Title 15 M.R.S. § 5826 has since been amended but not in
any way that affects this appeal. See P.L. 2023, ch. 196, § 1 (effective Oct. 25, 2023) (codified at
15 M.R.S. § 5826 (2026)).
The State seized $24,719 from Witham on March 9, 2022. See 15 M.R.S. §§ 5821(6) (2026); id.
§ 5826(2). This case had not yet gone to trial as of June 18, 2026, because the trial court stayed the
proceedings pending this appeal.
7
choosing and requesting that his funds be returned. See U.S. Const. amends. VI,
XIV; M.R.U. Crim. P. 41(j) (“A person aggrieved by an unlawful seizure of
property may file a motion in the Unified Criminal Docket for the return of the
property on the ground that it was illegally seized.”). At a hearing on Witham’s
motion on January 18, 2023, at which he was represented by counsel, he
requested an evidentiary hearing to address the asset forfeiture. The court
(R. Murray, J.) denied his request.
[¶8] The court (Larson, J.) held a jury trial from August 14 to 16, 2023,
on Counts 1 through 17. 9 The victim, the victim’s child, and three officers from
the Hancock County Sheriff’s Office testified in the State’s case-in-chief. At the
close of the State’s case-in-chief, Witham moved for a judgment of acquittal,
specifically arguing for acquittal on the kidnapping charges. The State opposed
the motion but conceded that it had not met its burden to prove Count 14,
criminal simulation. The court entered a judgment of acquittal as to Count 14
and denied Witham’s motion as to all other counts. Witham then put on his
case, calling two friends as witnesses and testifying on his own behalf.10 After
9 Witham elected to have Count 18 tried by the court, not the jury.
10 After Witham presented his case, he renewed his motion for judgment of acquittal as to the
remaining counts, which the court again denied.
8
the defense rested, and at the behest of the State, the court dismissed Counts 9
and 10, domestic terrorizing.11 The court then gave extensive jury instructions.
[¶9] The jury returned a guilty verdict on Count 1, kidnapping with a
dangerous weapon; Count 2, kidnapping; Count 5, aggravated assault; Count 6,
criminal restraint with a dangerous weapon; Count 8, domestic violence
criminal threatening with a dangerous weapon; Count 11, domestic violence
assault; Count 13, possession of a firearm by a prohibited person; Count 15,
endangering the welfare of a child with the use of a dangerous weapon; and
Count 17, criminal mischief. The jury was given a special verdict form and
separately reported that it did not find beyond a reasonable doubt that the
dangerous weapon used in Counts 1, 6, 8, and 15 was a firearm. The jury
deadlocked on Count 16, obstructing report of crime or injury, and the State
subsequently dismissed that count. The court found Witham guilty on
Count 18, violation of condition of release.
[¶10] In a letter dated August 28, 2023, and a motion filed on
September 1, 2023, Witham moved for a new trial and to vacate the judgment
of conviction, again arguing that, because his assets were seized and he could
11The State noted that, following the United States Supreme Court’s decision in Counterman v.
Colorado, 600 U.S. 66 (2023), the Maine Attorney General instructed district attorneys to dismiss all
terrorizing cases.
9
not afford the attorney of his choosing, his Sixth and Fourteenth Amendment
rights were violated. Following a hearing on September 22, 2023, the court
denied the motions, finding that “there had already been a hearing [on
January 18, 2023] on that motion for having the funds returned, and that
motion was denied by Justice Murray. . . . There was a hearing and it was
determined by the—Justice Murray that those funds would be drug proceeds.”
[¶11] On August 29, 2023, Witham requested that the court order a
mental-condition examination pursuant to 15 M.R.S. § 101-D(3) (2026). The
court held a hearing on September 22, 2023, on this and other post-trial
issues,12 at which Witham stated that his intent was to use the information
documented in the mental-condition examination at sentencing. The court
denied the request.
B. Witness-Tampering Case
[¶12] We turn to a description of the case involving the charges related
to tampering with a witness. Witham was charged by indictment on
October 9, 2020, in a matter with docket number HANCD-CR-2020-816, with
12 At the September 22 hearing, the court considered Witham’s motion for a new trial, taking into
account his arguments on issues regarding motions not heard, duplicative charges, enhancements,
his right to a speedy trial, and the use of a dangerous weapon. The court concluded that Counts 5 and
11 were duplicative, the law of merger applied, and Count 11 merged into Count 5 and therefore
Witham would be sentenced only on Count 5. The court also concluded that there was sufficient
evidence from which the jury could have found that a dangerous weapon, other than a firearm, was
used in the commission of Counts 1, 6, 8, and 15.
10
two counts of tampering with a witness, informant, juror, or victim (Class B)
(Counts 1 & 2), 17-A M.R.S. § 454(1-B)(A)(2), (B)(1) (2026); two counts of
tampering with a witness, informant, juror, or victim (Class C) (Counts 3 & 4),
17-A M.R.S. § 454(1)(A)(2), (B)(1); and one count of violation of condition of
release (Class C) (Count 5), 15 M.R.S. § 1092(1)(B) (2020). 13 He entered a
conditional guilty plea to Counts 1 and 514 on July 22, 2022, 15 and his sentencing
was continued to occur contemporaneously with sentencing in the
domestic-violence case, docket number HANCD-CR-2020-618.
C. Sentencing
[¶13] On October 6, 2023, the court held a sentencing hearing in docket
number HANCD-CR-2020-618 on Counts 1, 2, 5, 6, 8, 11, 13, 15, 17, and 18; and
in docket number HANCD-CR-2020-816 on Counts 1 and 5. At sentencing, the
court heard from the child’s father through the child’s stepmother, the victim
13 This statute has since been amended but not in any way that affects this appeal. See P.L. 2023,
ch. 293, § 1 (effective Oct. 25, 2023) (codified at 15 M.R.S. § 1092(1)(B) (2026)).
14 Counts 2, 3, and 4 were dismissed as a part of the conditional-plea agreement. Witham agreed
to a sentence concurrent with the pending domestic-violence case that would be capped at the
maximum sentence in the domestic-violence case. The parties agreed that should Witham be
acquitted of all charges in the domestic-violence case or the case be dismissed, the State would
recommend a time-served sentence. Witham was not acquitted of all charges, and the case was not
dismissed.
Although the docket record shows the conviction as being entered on July 22, 2022, it was not
15
a final judgment of conviction until after the sentence was imposed on October 6, 2023. The docket
record should be corrected on remand.
11
through a domestic-violence advocate, the child through the child’s clinician,
and the child’s clinician herself. The court also considered the State’s and
Witham’s sentencing memoranda. The court began by identifying the charge of
aggravated assault, Count 5, as the controlling offense and proceeded to focus
its Hewey analysis16 on that charge. In the first step of its analysis, the court
considered the nature and seriousness of the offense and found that there were
firearms involved over the course of the incident even though the jury was not
persuaded that a firearm was the dangerous weapon used in Counts 1, 6, 8, and
15. The court concluded that the basic sentence was eighteen years. In the
second step of its analysis, the court determined the maximum term of
imprisonment by considering aggravating and mitigating factors. The court
found as aggravating factors Witham’s criminal history, the impact on the
victim, Witham’s age (he was forty-four years old at the time of the offenses),
his lack of acceptance of responsibility, and his continued criminal conduct
during the pendency of the domestic-violence case. After considering the
mitigating factors of Witham’s active involvement in treatment and his strong
16 The court conducted the three-step process prescribed by 17-A M.R.S. § 1602 (2023) for the
sentencing on Class A, B, and C crimes. This is also known as the Hewey analysis. See State v. Hewey,
622 A.2d 1151, 1154-55 (Me. 1993). Section 1602 has since been amended, but not in any way that
affects this appeal. See, e.g., P.L. 2025, c. 420, § 1 (effective Sep. 24, 2025) (codified at 17-A M.R.S.
§ 1602 (2026)).
12
employment history, the court found that the aggravating factors outweighed
the mitigating factors and concluded that Witham’s final sentence for the
controlling offense was twenty-four years of incarceration, with all but
twenty-two years suspended, and six years of probation.17
D. Appeal
[¶14] Witham timely appealed from his judgments of conviction and
applied to appeal his sentence. 15 M.R.S. § 2151 (2026); M.R. App. P. 2B(b)(1).
On November 1, 2023, we consolidated Witham’s appeals from his judgments
of conviction, separately consolidated his applications to appeal his sentence,
and retroactively permitted the trial court to dismiss Count 5 in the
17 In docket number HANCD-CR-2020-618, Witham was also sentenced to the following terms of
incarceration, all running concurrently with the sentence on Count 5:
• Count 1, kidnapping with a dangerous weapon (Class A): eight years;
• Count 2, kidnapping (Class A): eight years;
• Count 6, criminal restraint with a dangerous weapon (Class B): five years;
• Count 8, domestic violence criminal threatening with a dangerous weapon (Class B): eight
years;
• Count 11 domestic violence assault (Class C): five years;
• Count 13, possession of a firearm by a prohibited person (Class C): five years;
• Count 15, endangering the welfare of a child with the use of a dangerous weapon (Class C):
five years;
• Count 17, criminal mischief (Class D): 364 days; and
• Count 18, violation of condition of release (Class E): six months.
As we discuss below, see infra ¶ 39, although the sentencing court merged Counts 5 and 11 at the
September 22, 2023, hearing, it did not merge the counts at sentencing nor was the merger reflected
in the judgment and commitment.
13
witness-tampering case, docket number HANCD-CR-2020-00816.18 The
Sentence Review Panel authorized the appeal of Witham’s sentence, which was
considered as part of Witham’s appeal. M.R. App. P. 20(g), (h).
II. DISCUSSION
A. Forfeiture
[¶15] Witham contends that the court erred as a matter of law when it
twice denied him an evidentiary hearing to litigate whether his funds seized in
an unrelated criminal proceeding were sufficiently connected to that criminal
offense to permit a potential forfeiture. Witham claims that the court violated
his Sixth and Fourteenth Amendment rights to counsel of his choosing and due
process, citing Luis v. United States, 578 U.S. 5, 22 (2016),19 and in doing so, also
violated 15 M.R.S. § 5828(1)(E)(1), which requires a court to order the return
of invalidly seized assets. See U.S. Const. amend. VI (“In all criminal
prosecutions, the accused shall enjoy the right . . . to have the Assistance of
In docket number HANCD-CR-2020-816, Witham was sentenced to eight years on Count 1,
18
tampering with a witness, informant, juror, or victim (Class B), to run concurrently with the
twenty-four-year sentence imposed on Count 5 in the domestic-violence case. The court
inadvertently failed to sentence Witham on Count 5 in the witness-tampering case, violation of
condition of release (Class C), which has now been retroactively dismissed.
19 Witham did not assert a claim under the Maine Constitution in the trial court or on appeal, and
we therefore deem any state constitutional claims waived. See State v. Tripp, 2024 ME 12, ¶ 20 n.9,
314 A.3d 101 (noting that the defendant failed to develop an argument on appeal based on the Maine
Constitution and therefore waived any state constitutional claims).
14
Counsel for his defence.”); U.S. Const. amend. XIV (“No State shall . . . deprive
any person of life, liberty, or property, without due process of law.”). Witham
contends that the court’s error was structural and therefore the remedy is a
new trial.
[¶16] The State argues that this issue is not properly before us because
the seizure occurred in an unrelated criminal docket. 20 In response, Witham
states that his motion to return seized funds was filed in four separate dockets,
including the drug-case docket, and that the relevant State’s attorneys were
present for the argument to the court about whether Witham was entitled to an
evidentiary hearing.
[¶17] We first consider whether we have jurisdiction to consider
Witham’s claim that the court erred as a matter of law by denying his requests
for an evidentiary hearing on whether his funds were unlawfully seized. As
noted above, the appeal before us is of Witham’s convictions in docket number
HANCD-CR-2020-618 for domestic violence occurring in June 2020, and docket
number HANCD-CR-2020-816 for witness tampering occurring in October
2020. The funds in question were seized from Witham almost two years after
the events at issue in this appeal, in connection with his charges in an entirely
The State raised additional arguments that need not be addressed in light of our jurisdictional
20
ruling.
15
different case involving drug trafficking, docket number
HANCD-CR-2022-00196. That matter remains open at the trial level and
nothing relating to that docket is before us. See supra n.8.
[¶18] Contrary to Witham’s argument, he has no constitutional right to
a pre-trial hearing regarding the seized funds when, as here, he has been
indicted for drug-trafficking offenses and forfeiture. The grand jury in the
drug-trafficking case found probable cause to believe that he committed the
offenses, and in that instance has also found probable cause to believe that the
funds should be forfeited. That is all the federal constitution requires, even if
the seizure of the funds impairs the defendant’s ability to hire counsel. Kaley v.
United States, 571 U.S. 320, 333 (2014); see United States v. Monsanto, 491 U.S.
600, 615-16 (1989).
[¶19] The forfeiture statute sets forth the process to determine the
validity of the seizure and forfeiture of assets. Section 5821 of Title 15 provides
for the forfeiture of “all money . . . furnished or intended to be furnished by any
person in exchange for a scheduled drug in violation of Title 17-A, chapter 45
[Maine’s criminal drug laws]; all proceeds traceable to such an exchange; and
all money . . . used or intended to be used to facilitate any violation of Title 17-A,
chapter 45.” 15 M.R.S. § 5821(6) (2026). Property subject to forfeiture under
16
section 5821 may be proceeded against by indictment or criminal complaint in
the related criminal proceeding. 15 M.R.S. § 5826(2) (2026). That is what
happened here: the forfeiture count was charged in the same indictment as the
drug-trafficking charges. Section 5826(4) provides that “[t]rial against
property charged by indictment . . . must be held in a single proceeding together
with the trial of the related criminal violation.” (Emphasis added.) Under
section 5826(4), therefore, the trial court here did not have jurisdiction to
determine whether the forfeiture was valid.
[¶20] Witham claims that, notwithstanding section 5826(4), he is
entitled to a pretrial hearing under section 5828. We disagree. Section 5828
provides for a prompt hearing, separate from the trial on the indictment, only
for “assets seized pursuant to [chapter 517 of Title 15].” 15 M.R.S. § 5828(1).
Aside from the fact that such a proceeding would still be separate from the
criminal charges in this case, that provision does not apply to the seizure about
which Witham complains. Instead, the process outlined in section 5828 applies
only when assets are seized pursuant to the process authorized in 15 M.R.S.
§ 5822 (2026),21 and there is no indication that is what occurred here.
21 Section 5822(6) permits any jurist to “issue, at the request of the attorney for the State, ex parte,
any preliminary order or process as is necessary to seize or secure the property for which forfeiture
is or will be sought and to provide for its custody. That order may include an order to a financial
institution or to any fiduciary or bailee to require the entity to impound any property in its possession
17
[¶21] The matters on appeal are convictions relating to offenses in which
no money was seized. We therefore conclude that we do not have jurisdiction
to consider Witham’s arguments regarding the forfeiture because no money
was seized in the matters in this appeal.
B. Specific Unanimity
[¶22] Witham contends that a specific-unanimity instruction should
have been given with respect to Counts 1, 2, 5, 6, 8, 11, 13, and 15.22
[¶23] Because Witham’s trial counsel did not request a
specific-unanimity instruction, we review the question of whether the court
erred in its jury instructions for obvious error. See State v. Haji-Hassan, 2018
ME 42, ¶ 18, 182 A.3d 145. “Obvious error occurs when jury instructions,
viewed as a whole, are affected by highly prejudicial error tending to produce
or control and not to release it except upon further order of the court. Process for seizure of the
property may issue only upon a showing of probable cause that the property is subject to forfeiture
under section 5821.” Section 5822(6) further provides that “seizure without the process may be
made when . . . [t]here is probable cause to believe that the property has been used or is intended to
be used in violation of any criminal law of this State, any other state or the United States.” Witham
was indicted for multiple counts of unlawful trafficking in scheduled drugs, and the criminal
forfeiture was commenced by the same indictment, and therefore the process outlined in section
5822 was not needed for the seizure of Witham’s money. See 15 M.R.S. §§ 5822(6), 5826(3).
22 Counts 1, 2, 5, 6, 8, 11, 13, and 15 are charges of the following offenses, respectively: kidnapping
the victim with a dangerous weapon (Class A); kidnapping the victim’s child (Class A); aggravated
assault of the victim (Class A); criminal restraint of the victim with a dangerous weapon (Class B);
domestic violence criminal threatening with a dangerous weapon (Class B); domestic violence
assault of the victim (Class C); possession of a firearm by a prohibited person (Class C); and
endangering the welfare of a child with the use of a dangerous weapon (Class C).
18
manifest injustice.” State v. Chase, 2023 ME 32, ¶ 13, 294 A.3d 154 (quotation
marks omitted). Obvious error requires “(1) an error, ‘(2) that is plain, (3) that
affects substantial rights, and . . . (4) that . . . seriously affects the integrity,
fairness, or public reputation of judicial proceedings.’” Id. (quoting State v.
Lajoie, 2017 ME 8, ¶ 13, 154 A.3d 132). In determining whether the court erred,
we evaluate the jury instructions in their entirety and consider the potential for
juror misunderstanding and “whether the instructions informed the jury
correctly and fairly.” Id. (quotation marks omitted).
[¶24] Witham argues that the trial court committed obvious error by
neglecting to give a specific-unanimity instruction, which resulted in
convictions that “were likely the result of numerous patchwork jury-votes
rather than unanimity about which incidents were actually committed.”
[¶25] “A specific unanimity instruction explains to jurors that they are
required to unanimously agree that a single incident of the alleged crime
occurred that supports a finding of guilt on a given count. Thus, if the State
alleges multiple instances of the charged offense, any one of which is
independently sufficient for a guilty verdict as to that charge, specific unanimity
instructions are proper.” State v. Russell, 2023 ME 64, ¶ 25, 303 A.3d 640
(emphasis added) (quotation marks omitted). The court should instruct the
19
jury on specific unanimity upon request from a party or on its own motion if
the State alleges multiple incidents that could each independently support a
finding of guilt on a certain charge. See Hanscom, 2016 ME 184, ¶ 16, 152 A.3d
632; State v. Villacci, 2018 ME 80, ¶ 1 n.1, 187 A.3d 576 (noting that the court
erred by not giving a specific-unanimity instruction even though neither the
defendant nor the State requested it).
1. Counts 1, 2, and 6
[¶26] We first address Witham’s arguments that on Counts 1
(kidnapping with a dangerous weapon), 2 (kidnapping), and 6 (criminal
restraint with a dangerous weapon) there was evidence of “seven separate
incidents that jurors might have felt constitute ‘restraint’” for both the victim
and the victim’s child.
[¶27] As a threshold matter, Witham does not argue on appeal that
Count 1, kidnapping with a dangerous weapon, and Count 6, criminal restraint
with a dangerous weapon, should be merged, nor did either party raise this
issue before the trial court. While we generally confine our review “to those
issues which have been identified and briefed by the parties,” we “will notice
an obvious error whether or not it is brought to the attention of the trial or
appellate court” when “the defendant’s constitutional right to a fair and
20
impartial trial is implicated.” See State v. Rusher, 468 A.2d 1008, 1009
(Me. 1983) (emphasis and quotation marks omitted). Therefore, we initially
review for obvious error any failure to merge duplicative counts. See id.; Chase,
2023 ME 32, ¶¶ 20-21, 294 A.3d 154.
[¶28] It is obvious error to punish a defendant twice for the same offense.
See Chase, 2023 ME 32, ¶¶ 20-21, 294 A.3d 154. Blockburger v. United States
provides that “where the same act or transaction constitutes a violation of two
distinct statutory provisions, the test to be applied to determine whether there
are two offenses or only one, is whether each provision requires proof of a fact
which the other does not.” 284 U.S. 299, 304 (1932). “‘If each statutory
provision requires a unique proof of fact, the Blockburger test is satisfied and
there is no double jeopardy violation . . . .’” Chase, 2023 ME 32, ¶ 22, 294 A.3d
154 (quoting Ayotte v. State, 2015 ME 158, ¶ 14, 129 A.3d 285). Here, we note
that both Count 1 and Count 6 allege that Witham “knowingly restrain[ed] [the
victim] with the use of a dangerous weapon, a firearm,” 23 but Count 1 alleges
the additional element of the intent to terrorize. Compare 17-A M.R.S.
§ 301(1)(A)(4) with 17-A M.R.S. § 302(1)(B)(1) (providing that kidnapping
requires intent to terrorize—among other alternatives—but that criminal
23 As noted above, the jury was not persuaded that Witham used a firearm.
21
restraint does not); see Chase, 2023 ME 32, ¶ 22, 294 A.3d 154. Because Count 1
requires a proof of fact that Count 6 does not but Count 6 does not require a
proof of fact that Count 1 does not, the Blockburger test is not satisfied and
Count 6 is a lesser-included offense of Count 1, and the court erred in not
merging the lesser-included offense (Count 6) into the greater offense
(Count 1). See Chase, 2023 ME 32, ¶¶ 23, 25, 294 A.3d 154; Blockburger, 284
U.S. at 304. To correct the constitutional double-jeopardy injury while
preserving multiple verdicts, we remand to the trial court for “‘resentencing on
a single conviction reflecting the merged counts.’” Chase, 2023 ME 32, ¶ 26, 294
A.3d 154 (quoting State v. Armstrong, 2020 ME 97, ¶ 15, 237 A.3d 185).
[¶29] Because we remand to the trial court to merge Count 6 into
Count 1, we need not address Witham’s argument for a specific-unanimity
instruction regarding Count 6 and instead turn to Count 1. For Count 1,
kidnapping with a dangerous weapon, Witham was charged with knowingly
restraining the victim with the use of a dangerous weapon with the intent to
terrorize the victim. The court instructed the jury on the definition of “restrain”
as follows:
Restrain means to restrict substantially the movements of another
person without that other person’s consent or other lawful
authority by removing the other person from the other person’s
residence or place of business or from a school, moving the other
22
person a substantial distance from the vicinity where the other
person was—is found, confining the other person for a substantial
period, either in the place where the restriction commences or in a
place to which the other person has been moved.
The jury found Witham guilty of kidnapping the victim with a dangerous
weapon but did not find that the dangerous weapon was a firearm. The only
item that the evidence showed was used in the course of the kidnapping that
was a dangerous weapon but not a firearm was a baseball bat. Therefore, there
is only one instance of conduct that the jury could unanimously identify was
true beyond a reasonable doubt and it was thus not obvious error to fail to give
a specific-unanimity instruction on Count 1. See Russell, 2023 ME 64, ¶ 28, 303
A.3d 640.
[¶30] Count 2 alleges kidnapping of the victim’s child and does not allege
the use of a dangerous weapon. The conduct alleged is thus entirely separate,
involving a different victim than the one in Counts 1 and 6. During closing
statements, the State described the restraint of the victim and her child to the
jury: “So the kidnapping starts in the Witham residence where they’re held in
the bedroom and not allowed to leave. It then continues when Mr. Witham tells
them get in the car and stay in the car. So you add that period of time on. And
then it continues again where he orders them out of the car and says you cannot
leave the garage. So you’ve got three places in which there’s continuity of
23
confinement.” The jury heard testimony from the victim and the victim’s child
regarding Witham’s constant threats to the victim and her child for them to
remain on the property or he would kill them, which all occurred in one
extended incident on or around June 24, 2020.
[¶31] The incident described by the State and the evidence provided to
the jury all indicate that the kidnapping of the victim’s child occurred as a
“single, continuous, incident” occurring on or about June 24, 2020, at Witham’s
residence. See State v. Rosario, 2022 ME 46, ¶ 35, 280 A.3d 199.24 The evidence
does not describe multiple discrete scenarios of restraint, as Witham argues,
but instead describes one continuous episode during which the victim’s child
was prevented from leaving the residence.
[¶32] The facts here are similar to the facts in State v. Pelletier, in which
we held that the evidence sufficiently supported a finding that the defendant
restrained the victim for a substantial period, despite arguments that the
defendant instead committed separate assaults. See 2023 ME 74, ¶¶ 24-25, 306
24 We do not interpret Rosario to apply only to cases in which there is a single-count indictment.
While Rosario involved one single charge of aggravated trafficking of scheduled drugs, the greater
context of our jurisprudence on specific unanimity involves whether a jury can unanimously agree
that one of multiple incidents “of the alleged crime occurred that supports a finding of guilt on a given
count,” implying the possible presence of other charges. 2022 ME 46, ¶ 34, 280 A.3d 199 (emphasis
added) (quotation marks omitted). Thus, each count is analyzed to determine whether multiple
incidents are alleged that could apply to that count, or whether only one continuous incident or one
isolated incident is alleged for that count.
24
A.3d 614 (holding, in a challenge to the sufficiency of the evidence, that there
was ample evidence in the record to support the court’s finding). In Pelletier,
th