State v. Crossman
790 A.2d 603 (2002)
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Rule of Law:
The element of 'entry' for burglary can be established by circumstantial evidence from which a rational fact-finder can reasonably infer that any part of the defendant's body, or an instrument used to effectuate a theft, crossed the threshold of the structure.
Facts:
- Peoples Heritage Bank had foreclosed on a vacant house near the residence of David and Nancy Carpenter.
- One evening, David Carpenter saw Merle Crossman and a woman at the vacant house with a black Nissan pickup truck; they claimed to be interested in buying it, and the truck bed was empty.
- A short time later, the Carpenters walked to the vacant house and discovered that the front door and sliding glass doors were missing and were now lying under a blanket near the driveway.
- The Carpenters then saw the same black pickup truck near the house again and heard low voices and rustling sounds.
- The Carpenters pursued the truck as it drove away, blocked its path, and identified the driver as Crossman.
- The truck's bed now contained the missing doors from the vacant house.
- As Crossman made a U-turn to flee, two of the doors fell out of his truck onto the road.
- Crossman stopped and threatened David Carpenter, stating, "Remember, Carpenter, I know where you live. You ain’t seen me."
Procedural Posture:
- Merle Crossman was indicted by a grand jury on charges of burglary and theft.
- Following a jury trial in the Superior Court (Waldo County), the trial court of first instance, the jury returned a verdict of guilty on both charges.
- The Superior Court entered a judgment of conviction and sentenced Crossman.
- Crossman (appellant) appealed the conviction to the Supreme Judicial Court of Maine, challenging the sufficiency of the evidence. The State of Maine is the appellee.
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Issue:
Does circumstantial evidence that a defendant removed exterior doors from a dwelling, which would logically require reaching inside the structure, suffice to prove the element of 'entry' for a burglary conviction beyond a reasonable doubt?
Opinions:
Majority - Alexander, J.
Yes, circumstantial evidence can be sufficient to prove the element of entry for a burglary conviction. The fact-finder is permitted to draw any reasonable inference that logically flows from the evidence, and the element of entry may be proven by circumstantial evidence alone. A burglarious entry occurs with the intrusion of any part of the body or an instrument used to facilitate the theft. Here, the jury could reasonably infer from the evidence that the hinges of a residential door are located on the inside of a dwelling. Based on this, and Crossman's own testimony that removing a door requires working from 'both sides,' a jury could rationally conclude that some part of Crossman's body or a tool he was using must have intruded into the home to remove the doors. Any one of these logical inferences is sufficient to support the jury's finding that Crossman 'entered' the home, satisfying the first element of burglary.
Analysis:
This decision affirms the principle that direct evidence is not required to prove the element of 'entry' in a burglary prosecution. It solidifies the power of circumstantial evidence and reasonable inferences drawn by the jury. The case clarifies that even a minimal intrusion—such as a hand, arm, or tool crossing the threshold of a structure to remove an exterior fixture like a door—is sufficient to constitute a legal entry. This precedent makes it more difficult for defendants to challenge burglary convictions solely on the basis that no witness saw them physically inside the building, thereby strengthening the prosecution's ability to secure convictions based on logical deductions from the physical evidence.
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