The Maine Supreme Judicial Court affirmed a lower court ruling that defendants cannot use probation revocation proceedings to collaterally attack their underlying criminal convictions, establishing clear procedural boundaries for challenging convictions in the state.
The decision came in *State of Maine v. Denis Lemieux* (Me. 2025), where Justice Mead wrote for the court that it would not reach the validity of Lemieux's underlying conviction because the trial court correctly ruled that probation revocation proceedings are not the proper venue for such challenges.
Denis Lemieux originally pleaded guilty to domestic violence terrorizing, a Class C felony, on Oct. 17, 2023, in Kennebec County Superior Court. Judge Daniel Mitchell sentenced Lemieux to three years of incarceration with all but eight months suspended, followed by probation with specific conditions.
The probation terms required Lemieux to refrain from all criminal conduct, obtain permission before moving, and maintain no contact of any kind with three named family members. These conditions were designed to protect the victims and ensure public safety following his domestic violence conviction.
On Feb. 5, 2024, the State filed a motion to revoke Lemieux's probation, alleging he violated multiple conditions. The primary allegations centered on threatening statements Lemieux allegedly made on social media about two of the family members he was prohibited from contacting. The State argued these statements constituted both direct and indirect contact in violation of protection orders and his probation conditions.
During a hearing on June 3, 2024, Judge Lipez found by a preponderance of the evidence that Lemieux's social media statements violated his probation conditions. The court determined the statements constituted contact with the protected family members, breaching both protection orders and probation terms.
The court also found that Lemieux inexcusably failed to comply with other probation requirements, including substance use evaluation and counseling, psychological evaluation and counseling, and notifying his probation officer before moving. These violations demonstrated a pattern of noncompliance with court-ordered supervision.
Based on these findings, Judge Lipez partially revoked Lemieux's probation. The partial revocation likely means Lemieux will serve additional time in custody while remaining on probation for the remainder of his sentence.
After the revocation hearing, Lemieux's defense team apparently argued that his underlying conviction was void, seeking to use the probation proceeding as a vehicle to challenge the original guilty plea and conviction. This strategy, known as a collateral attack, attempts to invalidate a conviction through proceedings other than direct appeal.
The Maine Supreme Judicial Court rejected this approach, affirming that probation revocation proceedings are limited in scope and cannot be used to challenge the validity of underlying convictions. The court emphasized that such challenges must be pursued through proper legal channels, such as post-conviction review proceedings or direct appeals.
The ruling clarifies an important procedural principle in Maine criminal law. While defendants retain various rights to challenge convictions through appropriate legal mechanisms, they cannot circumvent established procedures by raising constitutional or procedural challenges during probation proceedings.
This decision protects the integrity of the probation system by preventing defendants from relitigating issues that should have been raised during the original proceedings or through proper post-conviction procedures. It ensures that probation revocation hearings focus on whether defendants violated their supervision conditions, rather than becoming forums for broader constitutional challenges.
The court's approach aligns with the limited purpose of probation revocation proceedings, which is to determine whether a defendant has violated supervision conditions and what sanctions are appropriate. Allowing collateral attacks in these proceedings could undermine the efficiency and purpose of the probation system.
For defendants who believe their convictions are invalid, Maine law provides other avenues for relief, including post-conviction review under Maine Rule of Criminal Procedure 36B or direct appeals when timely filed. These procedures include more comprehensive protections and review standards appropriate for challenging convictions.
The *Lemieux* decision reinforces that procedural rules exist for good reasons and cannot be circumvented by creative legal arguments. Courts must maintain clear boundaries between different types of proceedings to ensure the justice system operates efficiently and fairly for all parties.
The case involved a five-justice panel including Chief Justice Stanfill and Justices Mead, Connors, Lawrence, and Douglas. The case was argued on Oct. 7, 2025, and decided on Dec. 23, 2025, showing the court's careful consideration of the procedural issues presented.
This ruling will likely be cited in future cases where defendants attempt similar strategies, providing clear precedent that probation proceedings have limited scope and cannot be used as vehicles for broader challenges to underlying convictions.