Summary
The Maine Supreme Judicial Court affirmed Margaretha Bjorkaryd-Bradbury's OUI conviction after concluding that a Scarborough police roadblock did not violate Maine's seatbelt-enforcement statute or the federal and state constitutional protections against unreasonable seizures. The court held that the roadblock had a general motor-vehicle-safety purpose, was minimally intrusive, and was reasonable under the applicable balancing test.
Topics
Practice areas
Questions Presented
- Whether the roadblock violated 29-A M.R.S.A. § 2081(4)(E) because it enforced the seatbelt law without first detaining motorists for suspected violations of another law.
- Whether the roadblock constituted an unreasonable seizure under the Fourth Amendment to the United States Constitution and the Maine Constitution because its primary purpose was unlawful.
Holdings
- A roadblock conducted for a broad motor-vehicle safety purpose, including but not limited to checking seatbelt violations, does not violate section 2081(4)(E).
- The roadblock was constitutional because it served a legitimate highway-safety purpose, was reasonably effective, and imposed only minimal intrusion on motorists.
Key quotations
“It goes without saying that our holding today does nothing to alter the constitutional status of the sobriety and border checkpoints that we approved in [Michigan Department of Police v. Sitz, 496 U.S. 444, 450-55, 110 S.Ct. 2481, 110 L.Ed.2d 412 (1990),] and [United States v. Martinez-Fuerte, 428 U.S. 543, 96 S.Ct. 3074, 49 L.Ed.2d 1116 (1976),] or of the type of traffic checkpoint that we suggested would be lawful in [Delaware v. Prouse, 440 U.S. 648, 99 S.Ct. 1391, 59 L.Ed.2d 660 (1979)].” (792 A.2d at 1085)
“Because the roadblock was reasonably effective in promoting the State's strong interest in preventing traffic accidents and promoting the health and welfare of its citizens, and the stops were minimally intrusive, the roadblock was constitutional.” (792 A.2d at 1086)
Factual background
The Scarborough Police Department operated a roadblock on Payne Road that stopped every southbound vehicle for a brief safety inspection. Although the log described it as a seatbelt roadblock, officers checked for seatbelt, registration, inspection, equipment, and other motor-vehicle violations. Approximately 1,020 vehicles were stopped, and the roadblock resulted in arrests, summonses, warnings, and equipment-defect notices. Defendant was stopped at approximately 5:00 p.m. and was detained further after an officer observed that her vehicle window was open only a few inches.
Procedural history
The District Court in Portland denied defendant's motion to suppress evidence, which challenged the constitutionality and statutory authority for the roadblock. The case was transferred to the Superior Court in Cumberland County, where defendant entered a conditional guilty plea and was convicted of OUI. The Supreme Judicial Court of Maine affirmed.