State v. Crossman
Supreme Judicial Court of Maine
790 A.2d 603 (2002)
A witness, Carpenter, saw Crossman (defendant) and a woman near a vacant, foreclosed house, later noticed several of its doors missing and stashed under a blanket in the driveway, and eventually saw Crossman driving away with those same doors in the bed of his truck. Police found the house ransacked with multiple doors gone. The State (plaintiff) charged Crossman with burglary and theft; at trial, Crossman testified he was experienced at removing doors and that doing so takes effort from both sides of the door, but no witness actually saw him step inside the house. The jury convicted him, and he appealed, arguing the evidence of entry was insufficient.
Whether, for purposes of burglary, an entry occurs when any part of the defendant's body passes the threshold of the structure.