State v. Flint, 12 A.3d 54

Flint challenged the stop and arrest; police followed a potentially speeding motorcycle, then tracked Flint after the rider entered a parking lot and fled into woods; canine confirmed scent leading to Flint; Flint exhibited impairment signs and refused field tests; he was handcuffed and detained, later arrested for operating under the influence based on observed impairment and license restriction history.
Officers had previously determined the motorcycle belonged to Flint and that his license prohibited alcohol in his system; O’Neill observed Flint’s conduct and Sawyer detected impairment through smell; handcuffs were used for safety due to lighting and concealment of hands.
The trial court denied the suppression motion, ruling the stop was permissible and necessary for officer safety; Flint was convicted on OUI and license restriction counts; the appellate issue is whether probable cause supported arrest rather than a mere Terry stop.
The Maine Supreme Judicial Court reviews de novo the application of law to undisputed facts and focuses on whether probable cause existed to arrest for OUI; the court ultimately holds probable cause existed, affirming the denial of the suppression motion.
The decision does not primarily rely on the permissibility of stop-related safety measures, because probable cause existed to justify arrest in this case.
The judgment was affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there probable cause to arrest Flint for OUI?	Flint	Flint	Yes; probable cause supported arrest.
Was the stop/encounter governed by Terry rather than arrest standards?	Flint	Flint	Court need not decide; probable cause supported arrest.
Did evidence from the scene justify continued detention beyond initial contact?	Flint	Flint	Not necessary to resolve separately; probable cause sufficed.

State v. Forsyth, 795 A.2d 66 (Me. 2002) (probable cause standard is flexible; officers’ view is objective)
State v. Cilley, 707 A.2d 79 (Me. 1998) (probable cause exists when facts would warrant cautious belief of impairment)
State v. Bradley, 658 A.2d 236 (Me. 1995) (probable cause can be more than suspicion but less than preponderance)
Texas v. Brown, 460 U.S. 730 (U.S. 1983) (probable cause standard relies on common-sense totality of circumstances)
State v. Lavoie, 1 A.3d 408 (Me. 2010) (review of law to undisputed facts de novo)
State v. Gorman, 854 A.2d 1164 (Me. 2004) (scope of evidence and legality of stops/arrests may be framed differently on appeal)
State v. Brochu, 237 A.2d 418 (Me. 1967) (early framework for distinguishing stops and arrests)