State of Maine v. Daniel H. Pelletier
125 A.3d 354
| Me. | 2015Background
- Daniel H. Pelletier was summonsed Feb 16, 2014 and charged with operating while license suspended (Class E) and operating after vehicle registration suspended; the registration charge was dismissed and he was convicted after a bench trial.
- Sentence: 30 days jail (27 suspended) and mandatory $500 fine under 29-A M.R.S. § 2412-A(3)(B).
- Pelletier did not dispute driving or suspension status; he raised two legal defenses on appeal only.
- Defense 1: Maine courts lack jurisdiction to enforce state law against him because he contends the “State of Maine” is a legal fiction and mere physical presence within lat/long bounds does not make him subject to state law.
- Defense 2: The statutory driver’s license requirement is facially unconstitutional as an infringement on a purported fundamental right to travel.
- The court treated the arguments as frivolous but addressed them to clarify the law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Maine courts have jurisdiction over persons physically present in Maine | Pelletier: “State of Maine” is a legal fiction; physical presence within lat/long does not render him subject to Maine law | State: Jurisdiction exists over persons and property within the State’s territory | Court: Jurisdiction exists over those physically present in the state; dismissed the contention as contrary to settled principles |
| Whether Maine’s driver’s license requirement is facially unconstitutional as an infringement on a fundamental right to travel | Pelletier: Licensing requirement restricts a purported constitutional right to travel | State: Licensing is a valid exercise of the State’s police power to protect public safety | Court: Licensing and registration requirements are constitutional limits on travel; upheld statute |
Key Cases Cited
- Pennoyer v. Neff, 95 U.S. 714 (establishes that a state has jurisdiction and sovereignty over persons and property within its territory)
- Hendrick v. Maryland, 235 U.S. 610 (state may require vehicle registration and driver licensing as valid police power)
- State v. Mayo, 75 A. 295 (Me. 1909) (upholding state regulation of motor vehicle operation as police power)
- Shaffer v. Heitner, 433 U.S. 186 (clarifies scope of in personam jurisdiction doctrine)
- Int’l Shoe Co. v. Washington, 326 U.S. 310 (jurisdictional due process standards)
- Showtime Entm’t, LLC v. Town of Mendon, 769 F.3d 61 (1st Cir. 2014) (noting limits on travel rights and upholding regulation in analogous context)