State of Maine v. Chad D. Lagasse, 2016 ME 158

On January 3, 2013 two masked men robbed a Caribou home at gunpoint; victim later identified one robber as Eric Mowatt.
Police arrested Mowatt; while in custody he initially denied, then admitted participation and identified Chad Lagasse as his accomplice and later provided a vehicle description and license plate number locating Lagasse.
Officers were instructed to arrest Lagasse if located; no arrest warrant was sought. On January 20 an officer followed a car matching the description and observed it veer abruptly without signaling.
The officer performed a high-risk felony stop, ordered the driver out, immediately recognized and arrested Lagasse; pills were found on/near Lagasse at arrest leading to an aggravated trafficking charge.
Lagasse moved to suppress the drug evidence arguing the arrest lacked probable cause (relying on Mowatt) and that the traffic stop was pretextual and lacked reasonable articulable suspicion; the Superior Court denied suppression.
After a jury convicted Lagasse of aggravated trafficking (acquitted on robbery-related counts), he appealed; the Maine Supreme Judicial Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable cause for warrantless arrest	State: Mowatt's statements and vehicle ID provided probable cause to arrest Lagasse	Lagasse: Mowatt was an unreliable informant; police lacked probable cause	Held: Probable cause existed — accomplice's identification and admission were sufficiently reliable
Reasonable articulable suspicion for traffic stop	State: Stop lawful; probable cause (and thus reasonable suspicion) existed	Lagasse: Stop was pretextual and lacked reasonable suspicion for investigatory stop	Held: Stop lawful — probable cause subsumed reasonable suspicion; traffic maneuver (veering without signal) justified stop

State v. Murphy, 130 A.3d 401 (Me. 2016) (standard for reviewing suppression hearing facts and inferences)
State v. Jones, 46 A.3d 1125 (Me. 2012) (review of evidence in suppression context)
State v. Parkinson, 389 A.2d 1 (Me. 1978) (definition of probable cause)
Maryland v. Pringle, 540 U.S. 366 (U.S. 2003) (collective knowledge and probable cause)
State v. Carr, 704 A.2d 353 (Me. 1997) (collective information for probable cause)
State v. Enggass, 571 A.2d 823 (Me. 1990) (objective probable cause test)
State v. Webster, 754 A.2d 976 (Me. 2000) (probable cause standard low threshold)
State v. Johnson, 434 A.2d 532 (Me. 1981) (conviction may rest on uncorroborated accomplice testimony)
State v. Jewell, 285 A.2d 847 (Me. 1972) (accomplice testimony can sustain conviction despite credibility issues)
State v. Sawyer, 314 A.2d 830 (Me. 1974) (accomplice inconsistencies do not automatically negate credibility)
State v. James, 206 A.2d 410 (Me. 1965) (jury may reconcile seeming inconsistencies in accomplice testimony)
State v. Rideout, 761 A.2d 288 (Me. 2000) (reasonable articulable suspicion required for investigatory stops)
State v. Menard, 822 A.2d 1143 (Me. 2003) (probable cause subsumes reasonable suspicion)
State v. Babcock, 361 A.2d 911 (Me. 1976) (relationship between probable cause and investigatory stops)