State of Maine v. Denis Lemieux

Summary

The court affirmed the revocation of Denis Lemieux's probation, holding that a probation-revocation proceeding is not a proper vehicle for collaterally attacking the validity or constitutionality of the underlying conviction. Because post-conviction review remained available to challenge that conviction, the trial court did not abuse its discretion by declining to address the constitutional claim. The opinion also distinguished the exceptional procedure previously created for ineffective-assistance claims arising from probation-revocation proceedings.