State v. Bennett-Roberson, 206 A.3d 303

Maine State Police trooper responded to a report of a "visibly intoxicated" man circling and repeatedly entering/exiting a described vehicle in a store parking lot. The caller identified himself, which the trooper found credible.
Trooper observed several people around the described vehicle and followed when three people entered and the car exited the lot; no traffic violations were observed.
Trooper initiated a traffic stop believing the vehicle was being operated by the intoxicated male; upon contact he immediately realized the driver was a female, Amanda Bennett-Roberson.
Bennett-Roberson produced registration but not a license; the trooper observed slurred speech and other signs suggesting possible drug impairment and she told him she had taken prescription medication.
Trooper asked her to exit the vehicle for field sobriety testing; she was arrested for OUI and driving without a license.
At suppression hearing the court found the initial stop valid but suppressed all evidence from the point the trooper determined the driver was female, reasoning the basis for the stop (suspected intoxicated male driver) had ceased to exist. The State appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the officer's post-stop actions (license check, ordering driver out) were reasonable when the original basis for the stop appeared to dissipate after learning the driver was female	Bennett-Roberson: once trooper realized driver was female, suspicion that an intoxicated male was driving dissipated and further detention was unreasonable	State: initial stop was valid and the trooper may reasonably expand inquiry based on information developed after stop; asking for license/registration and further investigation was related to the stop	Court vacated suppression order and remanded to evaluate whether information obtained after the stop justified ordering her out and whether that intrusion was reasonably related in scope to the initial stop.

State v. Blier, 162 A.3d 829 (Me. 2017) (standard for viewing facts in support of suppression rulings)
State v. Stade, 683 A.2d 164 (Me. 1996) (de novo review of legal conclusions where facts are undisputed)
Terry v. Ohio, 392 U.S. 1 (1968) (Terry stop two-part reasonableness framework)
State v. Hill, 606 A.2d 793 (Me. 1992) (post-stop license/registration checks can be reasonable even if initial basis dissipates after seizure)
State v. Huether, 748 A.2d 993 (Me. 2000) (officer may request ID after valid stop and expand inquiry based on new information)
State v. Garland, 482 A.2d 139 (Me. 1984) (officer may expand inquiry when additional evidence of wrongdoing is discovered during valid stop)
State v. Hewes, 558 A.2d 696 (Me. 1989) (court should consider all evidence up to the challenged seizure when resolving suppression motions)
Brown v. Texas, 443 U.S. 47 (1979) (balancing governmental interest against intrusion on individual liberty)