State v. McPartland

Summary

Mallory McPartland appealed her conviction for operating under the influence after the denial of her motion to suppress evidence obtained following an OUI roadblock. The Maine Supreme Judicial Court held that reasonable articulable suspicion is required to refer a motorist stopped at a lawful sobriety checkpoint for secondary screening and affirmed the judgment based on the combination of McPartland’s admitted alcohol consumption, the early morning hour, and her elevated speed.

Holdings

1. After a lawful initial sobriety-checkpoint stop, an officer must have an objectively reasonable, articulable suspicion that the motorist is impaired or that criminal conduct, a civil violation, or a threat to public safety has occurred, is occurring, or is about to occur before referring the motorist to secondary screening.
2. The totality of the circumstances—including McPartland's approach at approximately 2:00 a.m., her speed ten miles per hour above the posted limit, and her admission that she had consumed alcohol—provided an objectively reasonable, articulable suspicion that she was operating under the influence and justified secondary screening.

Questions Presented

1. What constitutional standard governs an officer's decision to refer a motorist lawfully stopped at an OUI sobriety checkpoint to secondary screening?
2. Whether the officer had an objectively reasonable, articulable suspicion of impairment sufficient to justify McPartland's referral to secondary screening.

Disposition

affirmed