first step analysis (Maine) · Go Syfert
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first step analysis in Maine

18 Maine opinions name it 2 courts 2000–2026 3 in the last five years

The cases below were cited by Maine courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (11)

CaseFollowedCited
State of Maine v. Nicholas W. Norrisgreen
me · 2023 · cited in 1 Maine opinions naming this issue, 2026–2026
1 sentence

2026See State v. Norris, 2023 ME 60, ¶ 33 , 302 A.3d 1 . 12 [¶21] Nonetheless, if an issue was not raised in the trial court and is therefore unpreserved, we review only for obvious error.

11
State v. Jonesgreen
me · 2012 · cited in 1 Maine opinions naming this issue, 2026–2026
2 sentences

2026See State v. Jones, 2012 ME 126, ¶ 35 , 55 A.3d 432 (“Our review of an alleged constitutional violation is de novo.”); State v. Plummer, 2020 ME 143, ¶ 10 , 243 A.3d 1184 (“We review de novo for misapplication of principle the basic sentence imposed at the first step of the analysis . . . .” (quotation marks omitted)). 9 Although Miller references the Due Process Clause in article I, section 6-A of the Maine Constitution, we confine our review to her argument under the federal constitution because she did not sufficiently develop the state constitutional argument before the trial court or on a

2026See State v. Jones, 2012 ME 126, ¶ 35 , 55 A.3d 432 (“Our review of an alleged constitutional violation is de novo.”); State v. Plummer, 2020 ME 143, ¶ 10 , 243 A.3d 1184 (“We review de novo for misapplication of principle the basic sentence imposed at the first step of the analysis . . . .” (quotation marks omitted)). 9 Although Miller references the Due Process Clause in article I, section 6-A of the Maine Constitution, we confine our review to her argument under the federal constitution because she did not sufficiently develop the state constitutional argument before the trial court or on a

11
State v. Watermangreen
me · 2010 · cited in 1 Maine opinions naming this issue, 2012–2012
2 sentences

2012See State v. Waterman, 2010 ME 45, ¶ 42 , 995 A.2d 243 .

2012See State v. Waterman, 2010 ME 45, ¶ 42 , 995 A.2d 243 .

11
Burson v. Freemangreen
scotus · 1992 · cited in 1 Maine opinions naming this issue, 2008–2008
2 sentences

2008See, e.g., Burson v. Freeman, 504 U.S. 191, 197-98 , 112 S.Ct. 1846 , 119 L.Ed.2d 5 (1992). 2 Mowles urges us to apply strict scrutiny rather than the less exacting review that the State proposes. [¶ 12] To determine the appropriate level of scrutiny, we must first identify the nature of the speech at issue.

2008See, e.g., Burson v. Freeman, 504 U.S. 191, 197-98 , 112 S.Ct. 1846 , 119 L.Ed.2d 5 (1992). 2 Mowles urges us to apply strict scrutiny rather than the less exacting review that the State proposes. [¶ 12] To determine the appropriate level of scrutiny, we must first identify the nature of the speech at issue.

11
Tibbetts v. Tibbettsgreen
me · 1979 · cited in 1 Maine opinions naming this issue, 2008–2008
1 sentence

2008See Tibbetts v. Tibbetts, 406 A.2d 70, 76-77 (Me.1979).

11
State v. Pfeilgreen
me · 1998 · cited in 1 Maine opinions naming this issue, 2007–2007
2 sentences

2007See State v. Pfeil, 1998 ME 245, ¶ 15 , 720 A.2d 573, 577 .

2007See State v. Pfeil, 1998 ME 245, ¶ 15 , 720 A.2d 573, 577 .

11
Garry D. Lloyd v. United Statesgreen
ca3 · 2005 · cited in 1 Maine opinions naming this issue, 2007–2007
1 sentence

2007See, e.g., Schardt, 414 F.3d at 1036 ; Lloyd v. United States, 407 F.3d 608, 613-15 (3d Cir.2005) (determining under Booker not Blakely); United States v. Price, 400 F.3d 844, 848-49 (10th Cir.2005); Johnson, 142 P.3d at 726-28 . [¶ 22] The United States Supreme Court’s decision in Summerlin determines the first step of the inquiry.

11
United States v. Joshua Price, Jr.green
ca10 · 2005 · cited in 1 Maine opinions naming this issue, 2007–2007
1 sentence

2007See, e.g., Schardt, 414 F.3d at 1036 ; Lloyd v. United States, 407 F.3d 608, 613-15 (3d Cir.2005) (determining under Booker not Blakely); United States v. Price, 400 F.3d 844, 848-49 (10th Cir.2005); Johnson, 142 P.3d at 726-28 . [¶ 22] The United States Supreme Court’s decision in Summerlin determines the first step of the inquiry.

11
Dale E. Schardt v. Alice Paynegreen
ca9 · 2005 · cited in 1 Maine opinions naming this issue, 2007–2007
1 sentence

2007See, e.g., Schardt, 414 F.3d at 1036 ; Lloyd v. United States, 407 F.3d 608, 613-15 (3d Cir.2005) (determining under Booker not Blakely); United States v. Price, 400 F.3d 844, 848-49 (10th Cir.2005); Johnson, 142 P.3d at 726-28 . [¶ 22] The United States Supreme Court’s decision in Summerlin determines the first step of the inquiry.

11
Hicks v. City of Westbrookgreen
me · 1994 · cited in 1 Maine opinions naming this issue, 2003–2003
1 sentence

2003STANDARD OF REVIEW [¶ 7] The first step in the analysis is the determination of prevailing party status, and “is a question of fact, subject to review for clear error.” Hicks v. City of Westbrook, 649 A.2d 328, 329 (Me.1994).

11
Pine Tree Telephone & Telegraph Co. v. Public Utilities Commissiongreen
me · 1993 · cited in 1 Maine opinions naming this issue, 2003–2003
1 sentence

2003Comm’n, 634 A.2d 1302, 1304 (Me.1993)). [¶ 16] The first step of our inquiry is to determine whether section 3206-A(2) is ambiguous; that is, “reasonably susceptible of different interpretations,” without deferring to the Commission’s conclusion that the statutory language is ambiguous.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Maine. Read the followed side critically anyway.

Also cited on this issue (14)

CaseCitedYears
State of Maine v. Noah Gaston green
me · 2021
2 sentences

2024“We review the trial court’s application of aggravating and mitigating factors in determining the maximum sentence for abuse of discretion.” State v. Gaston, 2021 ME 25, ¶ 36 , 250 A.3d 137 (quotation marks omitted). [¶27] Contrary to Lovejoy’s contention, the court did not “double-count” the consideration of Lovejoy’s mental state at the time of the offense and his post-murder conduct.

2021The court began the first step of the analysis by discussing the details specific to this murder that spoke to its “nature and seriousness.” Id. (quotation marks omitted).

22021–2024
State v. Holland green
me · 2012
2 sentences

2020Then, the court must “determine the maximum term of imprisonment to be imposed by considering all other relevant sentencing 27 factors, both aggravating and mitigating, appropriate to the case.” Id. § 1602(1)(B). [¶56] We “review the court’s determination of the basic sentence on the first step of the analysis de novo for misapplication of law.” State v. Holland, 2012 ME 2, ¶ 38 , 34 A.3d 1130 .

2020Then, the court must “determine the maximum term of imprisonment to be imposed by considering all other relevant sentencing 27 factors, both aggravating and mitigating, appropriate to the case.” Id. § 1602(1)(B). [¶56] We “review the court’s determination of the basic sentence on the first step of the analysis de novo for misapplication of law.” State v. Holland, 2012 ME 2, ¶ 38 , 34 A.3d 1130 .

22020–2020
State of Maine v. Brian Nichols green
me · 2013
2 sentences

2020We also review “the sentencing court’s determination of the basic period of incarceration for misapplication of sentencing principles” and “for an abuse of the court’s sentencing power.” State v. Nichols, 2013 ME 71, ¶ 13 , 72 A.3d 503 .

2020We also review “the sentencing court’s determination of the basic period of incarceration for misapplication of sentencing principles” and “for an abuse of the court’s sentencing power.” State v. Nichols, 2013 ME 71, ¶ 13 , 72 A.3d 503 .

22020–2020
State of Maine v. Theodore S. Stanislaw green
me · 2013
2 sentences

2020Stanislaw II, 2013 ME 43, ¶ 17 , 65 A.3d 1242 .

2020Stanislaw II, 2013 ME 43, ¶ 17 , 65 A.3d 1242 .

22020–2020
State of Maine v. Jahneiro Plummer green
me · 2020
2 sentences

2026See State v. Jones, 2012 ME 126, ¶ 35 , 55 A.3d 432 (“Our review of an alleged constitutional violation is de novo.”); State v. Plummer, 2020 ME 143, ¶ 10 , 243 A.3d 1184 (“We review de novo for misapplication of principle the basic sentence imposed at the first step of the analysis . . . .” (quotation marks omitted)). 9 Although Miller references the Due Process Clause in article I, section 6-A of the Maine Constitution, we confine our review to her argument under the federal constitution because she did not sufficiently develop the state constitutional argument before the trial court or on a

2026See State v. Jones, 2012 ME 126, ¶ 35 , 55 A.3d 432 (“Our review of an alleged constitutional violation is de novo.”); State v. Plummer, 2020 ME 143, ¶ 10 , 243 A.3d 1184 (“We review de novo for misapplication of principle the basic sentence imposed at the first step of the analysis . . . .” (quotation marks omitted)). 9 Although Miller references the Due Process Clause in article I, section 6-A of the Maine Constitution, we confine our review to her argument under the federal constitution because she did not sufficiently develop the state constitutional argument before the trial court or on a

12026–2026
State of Maine v. Dustan J. Bentley green
me · 2021
2 sentences

2024The purpose of the first step of the analysis is to place the crime “at a point on the continuum for the type of criminal conduct involved.” State v. Bentley, 2021 ME 39, ¶ 15 , 254 A.3d 1171 (quotation marks omitted).

2024The purpose of the first step of the analysis is to place the crime “at a point on the continuum for the type of criminal conduct involved.” State v. Bentley, 2021 ME 39, ¶ 15 , 254 A.3d 1171 (quotation marks omitted).

12024–2024
State v. Gray green
me · 2006
2 sentences

2024Sentencing courts may “refer to the same facts in the various steps of the 20 sentencing analysis so long as the court is weighing different considerations at each step.” State v. Gray, 2006 ME 29, ¶ 13 , 893 A.2d 611 (emphasis added and quotation marks omitted). [¶26] Lovejoy does not challenge the basic sentence set by the court in the first step of the analysis; he challenges the court’s analysis in the second step supporting the maximum sentence of forty-two years.

2024Sentencing courts may “refer to the same facts in the various steps of the 20 sentencing analysis so long as the court is weighing different considerations at each step.” State v. Gray, 2006 ME 29, ¶ 13 , 893 A.2d 611 (emphasis added and quotation marks omitted). [¶26] Lovejoy does not challenge the basic sentence set by the court in the first step of the analysis; he challenges the court’s analysis in the second step supporting the maximum sentence of forty-two years.

12024–2024
State of Maine v. Gabriel J. Hansen green
me · 2020
2 sentences

2020We review the sentencing court’s analysis at each step to determine “whether [it] disregarded the relevant sentencing factors or abused its sentencing power.” State v. Hansen, 2020 ME 43, ¶ 27 , 228 A.3d 1082 (quoting State v. Stanislaw, 2013 ME 43, ¶ 17 , 65 A.3d 1242 ). [¶11] By its nature, a double-counting claim relates to multiple steps of the sentencing analysis.

2020We review the sentencing court’s analysis at each step to determine “whether [it] disregarded the relevant sentencing factors or abused its sentencing power.” State v. Hansen, 2020 ME 43, ¶ 27 , 228 A.3d 1082 (quoting State v. Stanislaw, 2013 ME 43, ¶ 17 , 65 A.3d 1242 ). [¶11] By its nature, a double-counting claim relates to multiple steps of the sentencing analysis.

12020–2020
Maine Human Rights Commission v. City of Auburn green
me · 1979
2 sentences

2014Id. at 1265 . 35 [¶55] Here, Dussault satisfies the first step of the analysis: Coach Lantern’s refusal to include the HUD tenancy addendum in its leases effectively excludes one hundred percent of Section 8 recipients from renting from Coach Lantern.

2014Id. at 1265 . [¶ 55] Here, Dussault satisfies the first step of the analysis: Coach Lantern’s refusal to include the HUD tenancy addendum in its leases effectively excludes one hundred percent of Section 8 recipients from renting from Coach Lantern.

12014–2014
State v. Stanislaw green
me · 2011
1 sentence

2013Id. ¶ 11 & n. 8.

12013–2013
Fuhrmann v. Staples the Office Superstore East, Inc. green
me · 2012
1 sentence

2013Id.

12013–2013
Ring v. Arizona green
scotus · 2002
2 sentences

2007In Summerlin , the Court considered whether a new procedural rule announced in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), applied retroactively to cases on collateral review.

2007In Summerlin , the Court considered whether a new procedural rule announced in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), applied retroactively to cases on collateral review.

12007–2007
People v. Johnson green
colo · 2006
1 sentence

2007See, e.g., Schardt, 414 F.3d at 1036 ; Lloyd v. United States, 407 F.3d 608, 613-15 (3d Cir.2005) (determining under Booker not Blakely); United States v. Price, 400 F.3d 844, 848-49 (10th Cir.2005); Johnson, 142 P.3d at 726-28 . [¶ 22] The United States Supreme Court’s decision in Summerlin determines the first step of the inquiry.

12007–2007
Roe v. Flores-Ortega green
scotus · 2000
1 sentence

2000The court draws guidance from the Supreme Court's opinion in Roe v. Flores-Ortega, 528 U.S. ___ , 145 L.Ed.2d 985 (2000).

12000–2000

Statutes the citing opinions construe

ME § Me. Rev. Stat. tit. 17-A, § 1252-C (7) ME § Me. Rev. Stat. tit. 17-A, § 1602 (6) ME § Me. Rev. Stat. tit. 17-A, § 201 (6) ME § Me. Rev. Stat. tit. 15, § 2115 (4) ME § Me. Rev. Stat. tit. 17-A, § 1151 (4) ME § Me. Rev. Stat. tit. 17-A, § 1252 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 204 (1986–2026) CA 193 (1983–2026) IL 156 (1981–2026) OH 111 (1986–2026) IA 53 (1983–2024) WI 46 (1981–2025) OR 33 (1985–2024) KS 33 (1998–2026) MD 29 (1912–2025) FL 29 (1984–2025) MO 28 (1984–2024) NJ 27 (1983–2025) MI 26 (2007–2026) MN 25 (1986–2026) NM 25 (1997–2024) PA 25 (1982–2025) UT 24 (1904–2026) IN 23 (1981–2025) WA 23 (1975–2026) TN 22 (1995–2026) CT 21 (1989–2025) NY 20 (1981–2022) ME 18 (2000–2026) NC 18 (1981–2026) LA 16 (1990–2024) GA 15 (1988–2025) VT 14 (1993–2017) CO 14 (1985–2026) DC 14 (1988–2026) VA 12 (1993–2025) MA 11 (1996–2025) ID 11 (1986–2025) RI 11 (1984–2025) NE 10 (1995–2025) KY 10 (1990–2025) MT 9 (1995–2015) WV 8 (1982–2019) DE 8 (1992–2024) NH 8 (1990–2024) SD 5 (2002–2018) AK 5 (1988–2019) AZ 5 (1979–2013) MS 5 (2001–2015) ND 5 (2004–2014) HI 4 (1994–2017) NV 3 (2000–2022) OK 3 (2018–2025) AL 2 (2001–2001) AR 2 (2011–2016) VI 2 (2014–2023)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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