State of Maine v. Jacob R. Labbe Sr.

Summary

The court affirmed Labbe’s convictions for domestic violence stalking and two violations of a protective order. It held that the stalking statute was not unconstitutionally vague, that the evidence supported the verdict, that the charges were not de minimis, and that the challenged evidence was properly admitted for permissible purposes. The court further held that the First Amendment mens rea rule discussed in the later Supreme Court decision did not require proof of recklessness here because the conviction was based on persistent unwanted contact rather than the threatening content of Labbe’s words.