State v. Spain

Nancy Louise Spain (Defendant) had moved into the home of her ex-husband, Eugene Letendre, after she had been forced to move out of her apartment. One evening, Letendre returned to his home after drinking and went to sleep. At that time he did not see Defendant in the house. Early the following morning, Letendre awoke to the sound of his dog barking and a two-foot-high wall of flames rising up from the hardwood floor near his bed. After Letendre unsuccessfully attempted to put out the fire, and receiving several burns in the process, he ran to the kitchen and dialed 911. Firefighters arrived and extinguished the fire. Letendre was transported to a hospital to be treated for smoke inhalation and second-degree burns to six percent of his body. Fire investigators found a partially burned can of charcoal lighter fluid on Letendre’s bedroom floor. Defendant’s statement to police that she had been awakened on the couch by the fire differed from what was seen by firefighters who noted that the couch and living room was neatly made and did not look like it had been slept in. Defendant was charged with first-degree arson. At trial, Defendant’s claim that Letendre had accidentally started the fire with a lit cigarette was refuted by expert testimony, which indicated that the burn pattern on the floor indicated that it had been set deliberately. Defendant was convicted. In a victim impact statement presented prior to Defendant’s sentencing, Letendre told the court that his burned feet caused him daily pain and negatively impacted his ability to work and live. Although Defendant had no previous criminal history, the trial court sentenced her to 144 months in prison, which was a triple durational departure from the presumptive sentence of forty-eight months set forth in the state’s sentencing guidelines. The court of appeals affirmed the conviction and sentence and the Minnesota Supreme Court granted review.