State of Maine v. Luis Pabon

Summary

The court held that the trial court’s omission of the dwelling-place exception from the self-defense instruction was error, but did not constitute obvious error because the unpreserved error was not reasonably probable to have affected the verdict. The court clarified that Maine’s obvious-error review follows a four-part plain-error framework and requires a reasonable probability that the error affected the outcome. The judgment was affirmed because the evidence overwhelmingly indicated that Pabon was the initial aggressor. Silver, J., dissenting, would have vacated the convictions and remanded for a new trial because the incomplete instruction prevented the jury from fully evaluating self-defense.