Maine Revised Statutes

Me. Rev. Stat. tit. 17-A, § 351 (2026)

Consolidation

✓ current as of May 2026

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Conduct denominated theft in this chapter constitutes a single crime embracing the separate crimes such as those heretofore known as larceny, larceny by trick, larceny by bailee, embezzlement, false pretenses, extortion, blackmail, shoplifting and receiving stolen property. An accusation of theft may be proved by evidence that it was committed in any manner that would be theft under this chapter, notwithstanding the specification of a different manner in the complaint, information or indictment, subject only to the power of the court to ensure a fair trial by granting a continuance or other appropriate relief if the conduct of the defense would be prejudiced by lack of fair notice or by surprise. If the evidence is sufficient to permit a finding of guilt of theft in more than one manner, no election among those manners is required. [PL 2007, c. 475, §11 (AMD).]

SECTION HISTORY

PL 1975, c. 499, §1 (NEW). PL 1981, c. 317, §7 (AMD). PL 2007, c. 475, §11 (AMD).

Notes of Decisions

Cited in 26 cases, 1977–2020 · leading case: State of Maine v. Karl v. Kittredge, 2014 ME 90 (Me. 2014).

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State of Maine v. Karl v. Kittredge, 2014 ME 90 (Me. 2014). · cites it 3× “The court granted the motion over Kittredge’s objection because theft by receiving stolen property is an alternative basis for a theft charge and is subject to consolidation pursuant to 17-A M.R.S. § 351 (2013). The jury found Kittredge not guilty of burglary but guilty of both…”

State v. Rand, 430 A.2d 808 (Me. 1981). · cites it 3× “The Maine Criminal Code, however, under 17-A M.R.S.A. § 351 consolidated various modes of conduct into one single crime of theft; now, the receiver of stolen property is also a “thief.”

State of Iowa v. Betty Ann Nall, 894 N.W.2d 514 (Iowa 2017). “); Me. Rev. Stat. Ann. tit. 17-A, § 351. (Westlaw through ch.”

Jones v. State, 493 A.2d 1062 (Md. 1985). · cites it 2× “§ 14:67 (West 1981); Me. Rev. Stat. Ann. tit. 17-A, § 351 (1964); Mass.”

State v. Viger, 392 A.2d 1080 (Me. 1978). · cites it 2× “17-A M.R.S.A. §§ 351, 362. From the judgment of conviction the defendant brings this timely appeal, which we deny.”

State v. LaPlante, 534 A.2d 959 (Me. 1987). · cites it 2× “8 Under the consolidation provisions of 17-A M.R.S.A. § 351, 9 Rand had been charged not only with theft by unauthorized taking, section 353, but also with any other theft offense under chapter 15 of the Criminal Code that the evidence supported, including receiving stolen…”

State v. Liberty, 478 A.2d 1112 (Me. 1984). · cites it 2× “Title 17-A M.R.S.A. § 351 (1983) expressly provides that an “accusation of theft may be proved by evidence that it was committed in any manner that would be theft under this chapter_” 4 Therefore, the presid *1116 ing justice was not required to grant the motion to acquit on the…”

State v. Fox, 494 A.2d 177 (Me. 1985). · cites it 3× “§ 356, 2 Theft of *179 Lost, Mislaid or Mistakenly Delivered Property, had occurred and that the court had authority to make such a finding under 17-A M.R.S.A. § 351 (1983). 3 Fox requested and was granted time to brief the issue and the matter was continued.”

State v. Brasslett, 451 A.2d 890 (Me. 1982). · cites it 2× “The comprehensive consolidation permitted by 17-A M.R.S.A. § 351 gives recognition to the principle that it is not necessary in criminal pleading to make averments in indictments or complaints to the degree they become a recital of the evidence in proof of the charge.”

State v. Bouchard, 2005 ME 106 (Me. 2005). “” 17-A M.R.S.A. § 351 (1983) (emphasis added).”

Cardiel, 25 I. & N. Dec. 12 (BIA 2009). “”) (historical notes); Me. Rev. Stat. Ann. tit. 17-A, § 351 (1994) (“Conduct denominated theft in this chapter constitutes a single crime embracing the separate crimes such as those heretofore known as larceny, larceny by trick, larceny by bailee, embezzlement, false pretenses,…”

State v. Hayward, 156 A.3d 734 (Me. 2017). “See 17-A M.R.S. § 351 (2016) (“If the evidence is sufficient to permit a finding of guilt of theft in more than one manner, no election among those manners is required.”

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