State v. Whitney

Summary

The Maine Supreme Judicial Court held that a police officer unconstitutionally seized Daniel Whitney during a suspicionless roving patrol conducted after a single-vehicle accident. The court vacated the conviction and suppression order, concluding that the stop was not justified by reasonable articulable suspicion and was unreasonable under the Brown v. Texas balancing factors.

Holdings

1. The seizure was unconstitutional because Officer Willey stopped Whitney during a random, unsupervised roving patrol without an objectively reasonable, articulable suspicion that Whitney had committed, was committing, or imminently would commit a crime.
2. The seizure was unreasonable under the Brown three-factor test because the public concern was relatively limited, the stop was unlikely to materially advance the investigation, and the stop significantly interfered with Whitney's liberty.

Questions Presented

1. Whether Officer Willey's warrantless seizure of Whitney's vehicle was constitutional when the officer had no reasonable articulable suspicion of criminal conduct.
2. Whether the seizure was reasonable as an information-seeking stop under the three-factor test from Brown v. Texas, considering the public concern, the extent to which the stop advanced the public interest, and the interference with Whitney's liberty.

Disposition

reversed_and_remanded