State v. Journet

191 A.3d 1181 (Me. 2018) · Supreme Judicial Court of Maine · August 14, 2018

Summary

The Maine Supreme Judicial Court affirmed Michael Journet's conviction for aggravated trafficking of scheduled drugs. The court held that officers had probable cause to stop and arrest Journet without a warrant based on a cooperating individual's information, corroborating text messages, and police observations of the described vehicle and driver. The court therefore upheld the denial of Journet's motion to suppress the heroin and statements obtained after the arrest.

Holdings

  1. The officers had probable cause to arrest Journet without a warrant because the collectively known facts and reasonably trustworthy information, including the corroborated informant information and officers' observations, would warrant a prudent and cautious person to believe that Journet was committing heroin trafficking.
  2. The denial of Journet's motion to suppress was proper because the warrantless arrest was supported by probable cause.

Questions Presented

  1. Whether the officers had probable cause to make a warrantless arrest of Journet for a felony drug offense.
  2. Whether evidence seized and statements made after the arrest were subject to suppression because the arrest allegedly lacked probable cause.

Disposition

affirmed

Cases Cited (9)

  • State v. Kierstead, 2015 ME 45, ¶ 2, 114 A.3d 984(followed)
  • State v. Violette, 2016 ME 65, ¶¶ 3-4, 138 A.3d 491(not disputed)
  • State v. Lagasse, 2016 ME 158, ¶¶ 13-14, 149 A.3d 1153(followed)
  • State v. Parkinson, 389 A.2d 1, 8 (Me. 1978)(followed)
  • Maryland v. Pringle, 540 U.S. 366, 370-71, 124 S. Ct. 795, 157 L. Ed. 2d 769 (2003)(followed)
  • State v. Carr, 1997 ME 221, ¶ 7, 704 A.2d 353(followed)
  • State v. Enggass, 571 A.2d 823, 825 (Me. 1990)(followed)
  • State v. Heald, 314 A.2d 820, 828 (Me. 1973)(followed)
  • State v. Commeau, 2004 ME 78, ¶ 21 n.10, 852 A.2d 70(followed)

Cited In (0)

No citing cases on record yet.

Court Document

Open PDF
Loading document…