207 A.3d 191
Me.2019Background
- On Dec. 5, 2017 Reed‑Hansen was stopped by a Maine State Police trooper and later indicted for operating after revocation based on that stop.
- Reed‑Hansen timely requested all video/audio from the stop under M.R.U. Crim. P. 16(c); the prosecutor did not obtain or produce the trooper’s dash‑cam recording before the suppression hearing.
- At the May 11, 2018 suppression hearing the trooper testified and disclosed he was running a dash‑cam; the court paused the hearing for discovery issues.
- The trooper retrieved the brief dash‑cam video during the hearing; parties agreed on its contents: it showed Reed‑Hansen’s vehicle at the moment the trooper formed suspicion and showed operation of the vehicle.
- The State conceded it failed to deliver the requested video but argued the video lacked evidentiary value and caused no prejudice.
- The court found a discovery violation and, as a sanction, suppressed all evidence obtained from the stop (effectively ending the prosecution); the State appealed and the Supreme Judicial Court affirmed.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Reed‑Hansen) | Held |
|---|---|---|---|
| Did the State violate Rule 16(c) / discovery by failing to produce the dash‑cam? | No; video contained nothing exculpatory or discoverable. | Yes; video was material and relevant to defense preparation and possibly exculpatory. | Violation upheld: video was material/relevant under Rule 16(c); likely Brady exposure. |
| Should the court have viewed the video before ruling? | Yes; court erred by not reviewing the recording itself. | Not necessary; parties agreed on the video’s brief contents and described them to the court. | No error: court relied on parties’ agreed description; viewing was unnecessary. |
| Was suppression of evidence an appropriate sanction? | Suppression was excessive and an abuse of discretion that effectively terminated prosecution. | Significant sanction was appropriate given the presumptive prejudice and the State’s cavalier approach. | No abuse of discretion: suppression within court’s sanctioning authority and justified for instructional value. |
| Did the suppression require Fourth Amendment findings on the stop’s merits? | Court should have made Fourth Amendment findings. | Sanction was discovery‑based, not a merits ruling on constitutionality; Fourth Amendment findings unnecessary after sanction. | Correct: sanction did not require independent Fourth Amendment adjudication. |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (prosecution must disclose evidence favorable to accused)
- Giglio v. United States, 405 U.S. 150 (nondisclosure affecting witness credibility falls within Brady)
- State v. Poulin, 144 A.3d 574 (Me. 2016) (discovery obligations and tailored sanctions)
- State v. Hassan, 179 A.3d 898 (Me. 2018) (standard of review for discovery‑sanction appeals)
- State v. Twardus, 72 A.3d 523 (Me. 2013) (Brady materiality standard)
- State v. Reeves, 499 A.2d 130 (Me. 1985) (sanctioning principles)
- State v. Corson, 572 A.2d 483 (Me. 1990) (good faith relevant to sanction severity)