State of Maine v. Roger Ouellette

2024 ME 29
CourtSupreme Judicial Court of Maine
DecidedApril 18, 2024
DocketKen-23-12
StatusPublished
Cited by3 cases

This text of 2024 ME 29 (State of Maine v. Roger Ouellette) is published on Counsel Stack Legal Research, covering Supreme Judicial 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. Roger Ouellette, 2024 ME 29 (Me. 2024).

Opinion

MAINE SUPREME JUDICIAL COURT Reporter of Decisions Decision: 2024 ME 29 Docket: Ken-23-12 Argued: October 5, 2023 Decided: April 18, 2024

Panel: STANFILL, C.J., and MEAD, HORTON, CONNORS, LAWRENCE, and DOUGLAS, JJ.*

STATE OF MAINE

v.

ROGER OUELLETTE

STANFILL, C.J.

[¶1] Roger Ouellette appeals from a judgment of conviction of OUI

entered in the trial court (Kennebec County, Cashman, J.) upon a conditional

guilty plea. Ouellette entered the plea after the court (Stokes, J.) denied his

motion to suppress evidence the police obtained after stopping him in his

driveway. On appeal, Ouellette raises an argument he did not present to the

suppression court: that the stop was an unreasonable seizure under the

Fourth Amendment to the United States Constitution because it occurred

within the curtilage of his home without a warrant and without any applicable

exception to the warrant requirement. We affirm the judgment because we

conclude that the court’s failure to grant Ouellette’s motion on that ground did

* Although Justice Jabar participated in this appeal, he retired before this opinion was certified. 2

not constitute obvious error and because the court did not err in determining

that the stop was otherwise justified.

I. BACKGROUND

[¶2] The suppression court found the following facts, which are

supported by competent evidence in the record and which we view in the light

most favorable to the court’s decision. See State v. McNaughton, 2017 ME 173,

¶¶ 10, 28, 168 A.3d 807; State v. Connor, 2009 ME 91, ¶ 9, 977 A.2d 1003.

During the evening of February 1, 2020, a police officer was patrolling

Route 126 in Litchfield, looking for impaired drivers coming from a local

restaurant that he had heard was overserving alcohol. As the officer was

heading west toward the restaurant, he observed a vehicle driving east toward

him. The vehicle crossed over the center yellow double line and traveled

partially in the officer’s lane, enough so that the officer needed to move over in

his lane to pass the vehicle safely. The officer considered that the driver’s

operation was a violation of 29-A M.R.S. § 2051(1) (2023).

[¶3] The officer continued driving west until he lost sight of the vehicle’s

lights and then turned his cruiser around. After heading east for a short

distance, he regained sight of the vehicle and saw that it was parked, with its

lights still on, near a building that looked like a residence. The officer pulled 3

over and watched the vehicle for a few minutes to see if it would move. He then

continued driving east, past the vehicle, and pulled over at a side road and

waited again. After about ten minutes, he drove west past the vehicle again,

which was still parked with its lights on, and then turned around, parked, and

continued to watch.

[¶4] At some point, the officer saw the vehicle drive quickly across

Route 126 onto an icy “camp road” that was directly across from where the

vehicle had been parked. The officer followed the vehicle onto that road, and

he thought that it was driving faster than he would have expected, given the

conditions. He saw the vehicle turn into a driveway, and he then saw the

driver’s side door open and the driver, Ouellette, get out and slip on the icy

surface. He pulled into the driveway behind Ouellette’s vehicle, activated his

cruiser’s blue emergency lights, and then “approached [Ouellette] in the

driveway and questioned him.”

[¶5] Based on evidence obtained as a result of the stop, the State charged

Ouellette by complaint with OUI (Class D), 29-A M.R.S. § 2411(1-A)(A),

(5)(A)(3)(a)(i) (2023). After pleading not guilty, Ouellette filed a motion to

suppress evidence, arguing only that the officer lacked reasonable articulable

suspicion of wrongdoing sufficient to justify the stop under the United States 4

and Maine Constitutions. See State v. Sylvain, 2003 ME 5, ¶ 11, 814 A.2d 984

(describing the objectively reasonable articulable suspicion that must exist to

justify a brief, warrantless, investigatory vehicle stop).

[¶6] The court held an evidentiary hearing on Ouellette’s motion. During

the hearing, the parties and the court discussed, at some length, the legal basis

for Ouellette’s motion. Ouellette ultimately stated that his argument was

“twofold”: “the lack of [reasonable articulable suspicion], but it’s also a lack of

probable cause for . . . this seizure . . . [, which] turns into a de facto arrest with

. . . how the conversation unfolds.” The parties did not present oral closing

arguments; instead, they agreed to submit written memoranda after the

hearing.

[¶7] In his memorandum, Ouellette first argued that the officer lacked

reasonable articulable suspicion of either OUI or a traffic violation to support

the stop. He then argued that the stop was not one that could be justified absent

reasonable articulable suspicion because the severity of the officer’s

“interference with [his] liberty interests” outweighed the “gravity of the public

interest served by the investigatory stop.” In making this second argument,

Ouellette cited a line of cases in which we and the United States Supreme Court

have held that “that even in the absence of reasonable articulable suspicion, a 5

seizure for information-seeking purposes” may still be reasonable for

Fourth Amendment purposes. State v. LaPlante, 2011 ME 85, ¶ 8, 26 A.3d 337

(emphasis added); see State v. Whitney, 2012 ME 105, ¶ 10, 54 A.3d 1284

(“[S]pecial law enforcement concerns will sometimes justify highway stops

without individualized suspicion.” (quoting Illinois v. Lidster, 540 U.S. 419, 424

(2004))); Lidster, 540 U.S. at 424-27. Ouellette did not argue at any time in the

trial court that the seizure was unlawful even if it was supported by reasonable

articulable suspicion or probable cause because it had occurred within the

curtilage of his home without a warrant or an exception to the warrant

requirement.

[¶8] The court denied Ouellette’s motion in a written order. The court

concluded that no constitutional violation had occurred because the stop was

supported by reasonable articulable suspicion that Ouellette had violated the

motor vehicle statute requiring vehicles to be “operated as nearly as practical

entirely within a single lane” on a divided, two-lane public way, 29-A M.R.S. §

2051(1). Addressing Ouellette’s second argument, the court determined that it

therefore did not need to examine whether the stop would have been justified

even absent reasonable articulable suspicion of any wrongdoing. The court did

not make findings relevant to whether the stop was within the curtilage of the 6

home or to any exceptions to the warrant requirement, and Ouellette did not

move for further findings. Cf. M.R.U. Crim. P. 41A(d); State v. Sasso, 2016 ME 95,

¶¶ 18-19, 143 A.3d 124.

[¶9] Ouellette entered a conditional plea of guilty, and the court

(Cashman, J.) entered a judgment of conviction and imposed a sentence (stayed

pending appeal) of twenty days in jail, a $500 fine, and a license suspension.

Ouellette appeals. See M.R.U. Crim. P. 11(a)(2); 15 M.R.S. § 2115 (2023).

II. DISCUSSION

[¶10] Before us, Ouellette argues that the officer’s seizure of him was

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2024 ME 29, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-maine-v-roger-ouellette-me-2024.