State of Maine v. Maldonado

CourtSuperior Court of Maine
DecidedDecember 3, 2021
DocketKENcr-20-1479
StatusUnpublished

This text of State of Maine v. Maldonado (State of Maine v. Maldonado) 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. Maldonado, (Me. Super. Ct. 2021).

Opinion

STATE OF MAINE SUPERIOR COURT KENNEBEC, ss. CRIMINAL ACTION DOCKET NO. CR-20-1479

STATE OF MAINE ) ) Plaintiff, ) ORDER DENYING ) DEFENDANT'S MOTION TO V. ) SUPPRESS ) DAVID MALDONADO ) ) Defendant )

Before the court is Defendant David Maldonado's motion to suppress evidence obtained pursuant to a warrant containing a mistaken address in its no-knock provision. The Defendant's motion is based solely on article I, section 5 of the Maine State Constitution, which prohibits unreasonable searches and seizures. 1 I. Facts The parties have stipulated to the following facts: On July 24, 2020 Detective Benjamin Murtiff applied for a no-knock warrant for 15 Middle Street, Apartment 4, in Augusta. Factual Stipulations in re Motion to Suppress ,r 1. The magistrate issued the warrant requested with a no-knock provision, and Det. Murtiff and other officers executed the search warrant at 15 Middle Street, Apartment 4, on July 24. ,r,r 1-2. On August 12, 2020 Det. Murtiff drafted an affidavit in support of a search warrant for 85 Gage Street, Apartment 2, in Augusta. ,r 3. The affidavit established probable cause, and the magistrate issued the warrant with a requested no-knock provision. ,r,r 3-4. The warrant contained adequate particularity and was executed, without knocking or announcing, on August 12 at 85 Gage Street, Apartment 2. ,r,r 7, 10. Defendant Maldonado was inside the searched premises, and officers, relying on evidence obtained in the search, charged him with various crimes. ,r 14. The warrant contains a drafting error, originating from Det. Murtiff. ,r 15. The no-knock provision references an incorrect address: "Furthermore, [the magistrate] authorize[s] this to be a 'no-knock' warrant wherein law enforcement may execute this search warrant without prior notification to the occupants of 15 Middle Street, Apartment 4 ...." ,r 8. The affidavit had not contained this mistake, and the warrant makes no other reference to the incorrect address. ,r,r 6, 9. The parties also stipulate the following:

1 "Unreasonable searches prohibited. The people shall be secure in their persons, houses, papers and possessions from all unreasonable searches and seizures; and no warrant to search any place, or seize any person or thing, shall issue without a special designation of the place to be searched, and the person or thing to be seized, nor without probable cause -- supported by oath or affirmation." Me. Const. a11. 1, § 5.

1 There was no bad faith by Det. Murtiff in making the error. ~ 16. Det. Murtiff did not mislead the judge with false information or a reckless disregard for the truth. if 17. The warrant was issued with probable cause and was not facially deficient. ~~ 20-21. Det. Murtiff reasonably believed he was in compliance with the relevant requirements of the federal and Maine constitutions.~ 22. The Court infers from the record that the judge did not notice the drafting error. However, the paiiies stipulated that he did not abandon his judicial role.~ 18. II. Discussion The parties agree that the face of the warrant authorized a search of 85 Gage Street, Apartment 2. It did not, however, authorize a no-knock search of 85 Gage Street, Apartment 2. 2 The parties further agree that under the Fourth Amendment there is no federal remedy excluding evidence obtained from an unannounced search. They focus their arguments on article I, § 5, a provision in the state constitution resembling the Fourth Amendment. 3 With respect to the motion to suppress, two issues arise: first, whether article I, § 5 requires that officers knock and announce themselves before entering an area to be searched, and second, if so, whether article I, § 5 requires exclusion of evidence obtained in violation of that knock­ and-announce rule. The Defense argues that the Maine Constitution does protect against unannounced searches and offers exclusion of evidence as an appropriate remedy. The State counters that exclusion of evidence is not an available remedy under article I, § 5. 4 This Court concludes that article I, § 5 does protect against unannounced searches such that officers must knock and announce before they execute a search warrant. The "knock-and­ announce" rule has long existed in the federal common law, and in 1995, the U.S. Supreme Court recognized it as flowing from the Fourth Amendment. Wilson v. Ark., 514 U.S. 927,929 (1995). Before Wilson v. Arkansas, the Law Court declined to recognize such a provision flowing from article I,§ 5. State v. Hider, 649 A.2d 14, 15 (Me. 1994). Since these cases were decided, the Law Court has had the opportunity to recognize a state knock-and-announce rule but declined to address it. See State v. Reynoso-Hernandez, 2003 ME 19, ~ 6 n.2, 816 A.2d 826. However, the Law Court has also stated that article I, § 5 generally offers the same protection as the Fourth Amendment. E.g. State v. Patterson, 2005 ME 26, ~ 10, 868 A.2d 188; State v. Gulick, 2000 ME 170, ~ 9 n.3, 759 A.2d 1085. Moreover, recent Law Court decisions have noted the possibility that article I, § 5 in fact offers greater protection than the Fourth Amendment. E.g. Hutchinson, 2009 ME 44, ~ 18 n.9, 969 A.2d 923; State v. Glover, 2014 ME 49, ~ 10 n.2, 89 A.3d 1077. Because aiiicle I,§ 5 is at least coextensive with the Fourth Amendment, and the Supreme Court recognized the Fourth Amendment knock-and-announce rule after the Law Court decided Hider, this Court concludes that a state knock-and-announce rule flows independently from article I, § 5.

2 The State argues that the drafting error should not invalidate the entire warrant. The Court agrees. The warrant unambiguously authorizes a search of 85 Gage Street, Apartment 2. The drafting error only affects the no-knock provision. 3 Compare Me. Const. att. I, § 5, supra note 1 with U.S. Const. amend. IV ("The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized."). 4 The parties also argue as to the existence ofa good faith exception under the state constitution. The Court does not

address this argument because it resolves the motion on other grounds.

2 Having recognized a state knock-and-announce rule, the Court now takes up the issue of whether exclusion of evidence is a remedy for its violation. The State points to the federal reasoning against suppressing evidence obtained in violation of the knock-and-announce rule and Law Court precedent which has traditionally and generally adhered to federal Fouiih Amendment precedent where article I, § 5 issues are raised. The Defendant argues that the state constitution supports suppression, despite federal caselaw. Under the "primacy approach," when a state constitutional issue is properly raised and developed, Maine courts interpret the state constitution before relying on analogous federal constitutional law. State v. Larrivee, 479 A.2d 347,349 (1984). Maine courts may use federal decisions as "helpful guides" for understanding our state constitution, but ultimately the state document controls. State v. Flick, 495 A.2d 339, 344 (1985). The State argues that the Law Court has adopted Fourth Amendment precedent for issues under article I, section 5, and highlights two cases-State v. Hutchinson, 2009 ME 44, 969 A.2d 923, and State v. Glover, 2014 ME 49, 89 A.3d 1077-in which the Law Court has used federal caselaw in its analysis of unreasonable search and seizure.

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Related

Weeks v. United States
232 U.S. 383 (Supreme Court, 1914)
Mapp v. Ohio
367 U.S. 643 (Supreme Court, 1961)
Musser v. United States
414 U.S. 31 (Supreme Court, 1974)
Wilson v. Arkansas
514 U.S. 927 (Supreme Court, 1995)
Hudson v. Michigan
547 U.S. 586 (Supreme Court, 2006)
State v. Attaway
870 P.2d 103 (New Mexico Supreme Court, 1994)
State v. Foisy
384 A.2d 42 (Supreme Judicial Court of Maine, 1978)
State v. Gulick
2000 ME 170 (Supreme Judicial Court of Maine, 2000)
State v. Melvin
2008 ME 118 (Supreme Judicial Court of Maine, 2008)
Commonwealth v. Crompton
682 A.2d 286 (Supreme Court of Pennsylvania, 1996)
State v. Hider
649 A.2d 14 (Supreme Judicial Court of Maine, 1994)
State v. Fredette
411 A.2d 65 (Supreme Judicial Court of Maine, 1979)
State v. Hutchinson
2009 ME 44 (Supreme Judicial Court of Maine, 2009)
State v. Rees
2000 ME 55 (Supreme Judicial Court of Maine, 2000)
State v. Reynoso-Hernandez
2003 ME 19 (Supreme Judicial Court of Maine, 2003)
State v. Flick
495 A.2d 339 (Supreme Judicial Court of Maine, 1985)
State v. Patterson
2005 ME 26 (Supreme Judicial Court of Maine, 2005)
State v. Larrivee
479 A.2d 347 (Supreme Judicial Court of Maine, 1984)
State v. Roberson
225 P.3d 1156 (Court of Appeals of Arizona, 2010)
State of Maine v. Spencer T. Glover
2014 ME 49 (Supreme Judicial Court of Maine, 2014)

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Bluebook (online)
State of Maine v. Maldonado, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-maine-v-maldonado-mesuperct-2021.