State of Maine v. John E. Sasso, 143 A.3d 124

On March 28, 2014 an Ellsworth police officer (on underage‑drinking task force detail) observed 18‑year‑old John Sasso leave a convenience store, get into a car, and drive away on a rainy night.
The officer followed a short distance, observed no unsafe driving but noticed one brake/taillight appeared abnormally bright — described as a brake light that looked “stuck on.”
The officer stopped the vehicle, Sasso was found to be driving on a suspended license (suspended for a prior OUI) and was arrested for operating after suspension (Class E).
At the suppression hearing the officer, Sasso’s mother, and another witness testified about the taillight appearance; the court credited the officer and found “something out of whack with this car.”
Sasso argued the stop was pretextual (officer’s real motive was to investigate suspected underage alcohol purchase) and that there was no reasonable, articulable suspicion to justify the stop.
The motion to suppress was denied; Sasso pleaded nolo contendere conditionally, was convicted, and appealed. The Supreme Judicial Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the traffic stop was pretextual and unsupported by reasonable, articulable suspicion	Sasso: officer stopped the car to investigate underage drinking; no objective basis for the stop so it was pretextual	State: officer observed a malfunctioning/brighter brake light on a wet night creating a safety concern, providing objective basis for stop	Held: stop was supported by an objectively reasonable safety suspicion; therefore not an unlawful pretextual stop
Whether an officer’s subjective motive invalidates an otherwise objectively justified stop	Sasso: officer’s subjective intent to investigate other crimes should invalidate the stop	State: subjective motive is irrelevant if an objective justification exists	Held: Court follows Whren and Maine precedent — officer’s subjective motivation is irrelevant to the Fourth Amendment analysis; objective facts control

Whren v. United States, 517 U.S. 806 (officer’s subjective motive irrelevant where objective justification for stop exists)
State v. LaForge, 48 A.3d 218 (Maine recognition of Fourth Amendment protections in traffic stops)
State v. Sylvain, 814 A.2d 984 (traffic stop requires objectively reasonable, articulable suspicion)
State v. Haskell, 645 A.2d 619 (discussion of pretextual stops in Maine precedent)
State v. Bolduc, 722 A.2d 44 (clarifying objective standard over subjective motive post-Whren)
State v. Pinkham, 565 A.2d 318 (safety concerns can alone justify a stop)
State v. McPartland, 36 A.3d 881 (standards of review for suppression rulings)