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Maine Supreme Court Upholds Sexual Assault Conviction Despite Constitutional Challenges

The Maine Supreme Judicial Court affirmed Aaron C. Engroff's conviction on sexual contact charges, rejecting his appeals based on speedy trial violations and challenges to video evidence. The court ruled that a video interview of the victim did not violate confrontation or due process rights.

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4 min readcourtlistener
Seal of the Supreme Judicial Court of Maine

Case Information

Case No.:
2025 ME 83
Judges:
HORTON, J.

Key Takeaways

  • Maine Supreme Judicial Court affirmed Aaron Engroff's conviction on sexual contact charges despite constitutional challenges
  • Court rejected arguments that video interview evidence violated confrontation and due process rights
  • Legislature amended statute retroactively to apply to pending cases like Engroff's prosecution

The Maine Supreme Judicial Court affirmed the conviction of Aaron C. Engroff on charges of unlawful sexual contact and unlawful sexual touching, rejecting multiple constitutional challenges to his prosecution in a decision issued Aug. 26, 2025.

Engroff was convicted on two counts of Class B unlawful sexual contact under 17-A M.R.S. § 255-A(1)(E-1) and one count of Class D unlawful sexual touching under 17-A M.R.S. § 260(1)(C) following a jury trial in Kennebec County Superior Court. Justice Horton wrote the unanimous opinion for the six-justice panel.

The defendant raised three primary arguments on appeal: that the trial court erred in denying his motion to dismiss based on alleged speedy trial violations, that admitting a video interview of the victim violated his rights under the Maine Confrontation Clause and Maine Due Process Clause, and that the statute authorizing such video evidence did not apply to his case.

Regarding the speedy trial claim, the court disagreed that Engroff's constitutional rights were violated. The opinion notes that Engroff argued the court erred by denying his motion to dismiss based on speedy trial grounds, though the specific timeline details were not included in the available portion of the decision.

The more complex constitutional challenge centered on the admission of video evidence. Engroff argued that allowing the jury to view a video interview of the victim violated both the Maine Confrontation Clause and the Maine Due Process Clause, found in Article I, Sections 6 and 6-A of the Maine Constitution. These provisions guarantee defendants the right to confront witnesses against them and ensure due process protections.

The court rejected these constitutional arguments, finding that the video interview's admission did not violate either constitutional provision. This ruling aligns with evolving jurisprudence around victim interviews in sexual assault cases, where courts must balance defendants' confrontation rights with practical considerations in prosecuting such crimes.

A significant statutory interpretation issue also emerged in the case. Engroff challenged whether 16 M.R.S. § 358, which authorizes the admission of certain video interviews, applied to his prosecution. The court agreed with Engroff's narrow statutory argument, finding that section 358 in its original form did not apply to cases that were already pending when the statute was enacted, including Engroff's case.

However, this statutory victory proved pyrrhic for the defendant. The court noted that the Maine Legislature had since amended section 358 to apply retroactively to cases like Engroff's, effectively closing the legal loophole he had identified. This legislative change allowed the court to affirm the conviction despite agreeing with Engroff's original statutory interpretation.

The case was argued before the Maine Supreme Judicial Court on Dec. 10, 2024, with the decision issued approximately eight months later. The panel included Chief Justice Stanfill and Justices Mead, Horton, Connors, Lawrence, and Douglas.

The decision represents an important precedent for Maine sexual assault prosecutions, particularly regarding the use of victim interview videos as evidence. The court's analysis of the confrontation clause issues provides guidance for prosecutors and defense attorneys handling similar cases.

The ruling also demonstrates the Legislature's authority to clarify statutory application retroactively, though such changes typically face constitutional scrutiny regarding ex post facto protections. The court's acceptance of the legislative amendment suggests it found no constitutional impediment to the retroactive application.

For sexual assault prosecutions in Maine, the decision reinforces prosecutors' ability to use video interviews under appropriate circumstances while maintaining defendants' constitutional protections. The careful constitutional analysis shows courts will scrutinize such evidence but will not categorically exclude it when proper procedures are followed.

The case also highlights the importance of speedy trial protections, though the court's rejection of Engroff's claim suggests the timeline in this prosecution fell within constitutional bounds. Sexual assault cases often involve extended investigation periods and complex evidence gathering, making speedy trial analysis particularly fact-specific.

Looking ahead, the decision provides clarity for Maine courts handling similar evidence questions in sexual assault prosecutions. The combination of constitutional analysis and statutory interpretation offers a framework for evaluating video interview evidence while protecting both victims and defendants' rights.

Engroff's conviction stands affirmed, and the precedential value of the decision will likely influence how Maine courts handle video evidence in future sexual assault prosecutions. The ruling balances the practical needs of prosecution with constitutional protections, reflecting ongoing evolution in how courts address these sensitive cases.

Topics

sexual contactsexual touchingspeedy trialconfrontation clausedue processvideo evidencevictim interview

Original Source: courtlistener

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