State v. Blier, 162 A.3d 829

Late evening traffic stop: officer observed a vehicle with defective license plate lights, followed it with flashing "wig wag" headlights, and the car turned into a driveway.
Driver (Blier) exited his vehicle, went to his house, entered an enclosed porch, and began to unlock the door while the officer followed onto the porch and spoke through the threshold.
Officer told Blier he needed to come outside to produce license, registration, and insurance; Blier walked back to his car to retrieve documents.
While standing over Blier as he retrieved documents, the officer smelled alcohol, conducted field sobriety tests, and arrested Blier for OUI based on test performance.
Motion court suppressed evidence, concluding the officer unlawfully seized Blier by ordering him out of his home without probable cause or exigent circumstances; State appealed and the Supreme Judicial Court reviewed de novo.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ordering Blier out of his house and pursuing him across the threshold was an unlawful seizure/arrest	Blier: officer lacked probable cause to arrest; ordering him out of the house was a seizure that violated the Fourth Amendment	State: officer reasonably pursued a vehicle that failed to stop for flashing lights; facts gave probable cause to arrest for failure to stop and justified the pursuit into curtilage	Court: officer had probable cause to arrest for failure to stop; seizure was lawful and suppression was vacated
Whether officer's traffic stop required and met articulable suspicion/probable cause standards	Blier: officer only had suspicion of a civil traffic violation (defective lights), not criminal activity to justify arrest across the threshold	State: initial reasonable suspicion supported stop; officer’s observations (continued flight, entering house while cruiser behind) supported probable cause for failure-to-stop offense	Court: initial stop was supported by reasonable suspicion and the objective facts established probable cause for failure to stop, a Class E crime, therefore arrest was lawful

State v. Collier, 66 A.3d 563 (2013) (standards for reviewing suppression fact findings)
State v. Bailey, 41 A.3d 535 (2012) (review standard: factual findings for clear error, legal conclusions de novo)
State v. Donatelli, 995 A.2d 238 (2010) (limits on investigatory stops and when detention becomes an arrest)
State v. Flint, 12 A.3d 54 (2011) (probable cause suffices to justify arrest that follows investigatory stop)
State v. Lagasse, 149 A.3d 1153 (2016) (definition and low threshold of probable cause)
State v. Pease, 520 A.2d 698 (Me. 1987) (pursuit "immediately and fairly continuously" into curtilage following crime scene)
State v. Gulick, 759 A.2d 1085 (2000) (Maine Constitution provides protections coextensive with Fourth Amendment)

Order: suppression vacated; case remanded for further proceedings.