State of Maine v. Eric M. Martin, 120 A.3d 113

MDEA investigated importation of oxycodone from Detroit; a confidential informant arranged a delivery involving a man called “Al” and identified a deliveryman (Ricci Wafford) whose phone was tracked by warrant.
Officers followed Wafford’s car into Maine; when it was stopped on I-95 there were two occupants: Wafford (driver) and Eric M. Martin (passenger). Both were ordered out and handcuffed.
Detective McQuade patted down both men for weapons/contraband and felt what he believed was a plastic bag in Martin’s lower groin area; he could not retrieve it from pockets.
MDEA Supervising Special Agent Gillen reached into Martin’s waistband/underwear and removed a bag containing 98 oxycodone pills; another bag of 50 pills was later found on the ground nearby.
Martin was indicted for trafficking and importation and moved to suppress the pills seized from his person, arguing the warrantless search violated the Fourth Amendment and Maine Constitution; the trial court granted suppression.
The State appealed, arguing the search was supported by probable cause, exigent circumstances, and alternatively was incident to arrest or subject to inevitable discovery; the Supreme Judicial Court vacated the suppression order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers had probable cause to search Martin	Martin: No particularized evidence tying him to drugs beyond presence in the car	State: Totality of circumstances (CI, tracking, travel to deliver drugs, bag felt on person) gave fair probability contraband on occupants	Held: Yes — Pringle permits inference of common enterprise; probable cause extended to passenger
Whether exigent circumstances justified a warrantless search	Martin: No exigency shown to preclude obtaining a warrant	State: Drugs can be quickly destroyed/disposed; another bag was later found on ground indicating disposal was possible	Held: Yes — exigency present because narcotics easily destroyed/disposed and a bag was discarded nearby
Whether search was lawful as incident to arrest	Martin: Search exceeded bounds of protective search and not justified as incident	State: Alternatively, discovery on ground would permit arrest and search incident to arrest	Held: Court did not need to decide because probable cause + exigency sufficed; alternative not reached
Whether inevitable discovery applies	Martin: Suppression appropriate because initial search unlawful	State: Even if search defective, later discovery of pills on ground would inevitably lead to lawful discovery of pills on Martin	Held: Not necessary to decide given primary holdings, but court noted inevitable discovery would likely apply if defect existed

Maryland v. Pringle, 540 U.S. 366 (inference of joint possession among car occupants supports probable cause)
Ybarra v. Illinois, 444 U.S. 85 (search of a patron in a public place cannot rest solely on link to premises)
United States v. Di Re, 332 U.S. 581 (guilt-by-association limitations on searches of persons)
United States v. Tiru-Plaza, 766 F.3d 111 (warrantless searches presumed unreasonable absent exception)
United States v. Samboy, 433 F.3d 154 (exigent circumstances in drug cases where evidence can be quickly destroyed)
United States v. Brown, 500 F.3d 48 (probable cause to arrest/ search based on totality; constructive possession in vehicle)
State v. Smith, 593 A.2d 210 (Me. 1991) (approved warrantless search of jacket pocket when marijuana could be destroyed)