State of Maine v. Dumas

CourtSuperior Court of Maine
DecidedMarch 19, 2009
DocketPENcr-07-1018
StatusUnpublished

This text of State of Maine v. Dumas (State of Maine v. Dumas) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Maine v. Dumas, (Me. Super. Ct. 2009).

Opinion

STATE OF MAINE SUPERIOR COURT PENOBSCOT, ss. CRIMINAL ACTION D?~~~T N~: ~R-p7~}rl.~!,; STATE OF MAIN~, FILED & ENTERED .. 'i

SUPFPIOR r.nIIRT ORDER ON DEFENDANT'S v. MAR 1 6 2009 MOTION TO SUPPRESS ITEMS OF PROPERTY JOSPEH DUMAS PENOBSCOT COUNTY

Defendant.

Before the Court is Defendant Joseph Dumas' Motion to Suppress Items of

Property dated March 31, 2008. This motion was consolidated for hearing with Mr.

Dumas' Motion to Suppress Statements of the same date. Hearing on both motions was

conducted on January 6, 2009. Mr. Dumas has been indicted for the murder of Mario

"Sonny" Litterio, which allegedly occurred on or about November 8, 2007. Mr. Dumas

is represented by Attorneys Rick Hartley and Peter Cyr. The State of Maine is

represented by Assistant Attorneys General Andrew Benson and Donald Macomber.

FACTUAL BACKGROUND

On November 9,2007, Joseph Dumas was taken to the Penobscot Valley Hospital

in Lincoln, Maine for treatment of injuries sustained in a serious motor vehicle accident.

He had been driving on Route 2 in Lincoln, when he apparently crossed the centerline

and struck a southbound tractor-trailer. When he arrived at the hospital, a doctor sent

orders to X-Ray Technician Jennifer Ward to take x-rays of the Defendant. According to

the sworn testimony of Ms. Ward, she first saw Mr. Dumas at approximately 11 a.m. in a

treatment room, at which time he was lying on a backboard upon a wheeled stretcher.

She told him that she needed to take him across the hall to take x-rays, which she did.

1 She explained that because he was on a backboard and had been in an accident that she

was required to do a "cross-table lateral C-spine" x-ray to make sure that his neck and

spine were stable. (Tr. at 108). She took a few of these x-rays while he was lying down,

and noted that he was upset. She asked him if everything was all right and why he was so

upset. He said he wanted to see his wife and Ms. Ward told him that as soon as they were

done she would bring his wife in to be with him. At that point he told her that he would

not be able to see his wife again, that he was going to jail, and that he had shot someone.

She described his demeanor as "whimpery," but stated he was not sobbing. (Tr. at 110).

With the assistance of another medical provider, she transferred Mr. Dumas onto

an x-ray table. It was then that she had to remove his coat and upon doing so she noticed

a "whole pocketful of bullets." (Tr. at Ill). She testified that she had previously

removed his pants while he was on the stretcher and that she had found a knife, some

Marlboro Light cigarettes, and a container in his pants. She noted that she is required to

take off or remove any item of clothing worn by a patient that might have metal on it.

(Tr. at 101).

Ms. Ward decided to turn over the items she removed from his pants and coat to

law enforcement officers who were waiting outside his room and has admitted that Mr.

Dumas' statement that he had shot someone factored into her decision to turn over the

items. She testified, "I went out ofthe door, checked my [x-ray] image and handed those

over," referring to the items'ofproperty she had removed from Mr. Dumas' clothes. (Tr.

at 114). She further testified that no law enforcement officer asked her or demanded that

she take the items or turn them over, but that it was her decision. (Tr. at 102).

2 She also testified that she was certain that the hospital had a policy about what to

do with a person's property once it is taken from them, but she did not testify as to what

the policy was. (Tr. at 113). She did not have a conversation with Mr. Dumas about

taking his clothing other than telling him that she had to remove his pants. She never told

him that she was going to give any of his property to the police. (Tr. at 113). She

testified that if she had not turned the property over to the police, it would have been

stored in a plastic bag and been moved along with the patient to the room in which the

patient would be treated. It would then be returned to the patient when the patient's stay

was completed. (Tr. at 115).

FINDINGS AND CONCLUSIONS

The Defendant relies in his argument upon a line of cases in which property was

seized from criminal defendants in emergency room or hospital settings. The argument is

that a defendant, such as Mr. Dumas, does not forfeit his possessory rights to clothing

simply by walking into, or being transported emergently to, a hospital. In United States

v. Neely, 345 F.3d 366, 368 (5th Cir. 2003), the defendant was admitted and treated for a

gunshot wound. Emergency personnel had to remove his clothing in order to treat him,

which they did by cutting it away from his body. /d. The hospital policy was to

inventory the property, place it in a plastic bag, and put the clothing into a storage room.

Id. It was maintained for five to six days, after which it was thrown away. Id. While the

defendant was in surgery, an officer requested that medical personnel give him the

clothes, which they did. Id. The government argued that exigent circumstances justified

the seizure, and also that the defendant lost his privacy interest in the clothes by wearing

them into a hospital. Id. at 368-69. The court rejected those arguments, held that the

3 hospital did not 'jointly" possess the clothes, and found the seIzure to be

unconstitutional. Id. at 370-71. The Court, quoting People v. Yaniak, 738 N.Y.S.2d 492,

495-96 (Yates County Ct. 200 I), held that "once the clothing is taken from the patient

and secured by the hospital, the hospital becomes a bailee and the employees have no

authority to permit the police to search or test the clothes without the consent of the

owner." Neely, 345 F.3d at 369-70. The court in Yaniak went on to hold that since the

hospital had no authority to hand over the clothes, the only way the police could have

legally taken them without a warrant - absent application of a recognized exception to the

warrant requirement - was if there was evidence that the defendant had abandoned his

clothes. Yaniak, 738 N.Y.S.2d at 496. Because the hospital's placement of the items in a

bag was evidence to the contrary - that the clothes were being stored until they might be

returned - the court was unpersuaded by the government's position. Id.

The Court has reviewed the cases cited by the defense. In all of the cases in

which courts agreed that an unconstitutional seizure had occurred in hospital settings,

such as Neely and Yaniak,l the police either asked hospital personnel for the property and

received it, or simply took the property with the acquiescence of hospital personnel. In

the case at bar, there is no evidence that the police either demanded or even asked for the

Defendant's property. The evidence here suggests that the x-ray technician acted on her

own, out of a sense of obligation, or because she was trying to be of assistance to law

enforcement after hearing that Mr. Dumas had shot someone.

I This is true also of United States v. Nanos, 2006 U.S. Dist. LEXIS 87434 (D. Me. 2006), a case in which the defense asserts that the government conceded the defendant's Motion to Suppress.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Neely
345 F.3d 366 (Fifth Circuit, 2003)
Burdeau v. McDowell
256 U.S. 465 (Supreme Court, 1921)
Miranda v. Arizona
384 U.S. 436 (Supreme Court, 1966)
Coolidge v. New Hampshire
403 U.S. 443 (Supreme Court, 1971)
Davis v. United States
512 U.S. 452 (Supreme Court, 1994)
State v. Holloway
2000 ME 172 (Supreme Judicial Court of Maine, 2000)
State v. LeGassey
456 A.2d 366 (Supreme Judicial Court of Maine, 1983)
State v. Grant
2008 ME 14 (Supreme Judicial Court of Maine, 2008)
State v. Higgins
2002 ME 77 (Supreme Judicial Court of Maine, 2002)
State v. Lavoie
562 A.2d 146 (Supreme Judicial Court of Maine, 1989)
State v. Hewes
558 A.2d 696 (Supreme Judicial Court of Maine, 1989)
People v. Yaniak
190 Misc. 2d 84 (New York County Courts, 2001)

Cite This Page — Counsel Stack

Bluebook (online)
State of Maine v. Dumas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-maine-v-dumas-mesuperct-2009.