State v. Johnson, 95 A.3d 621

Johnson appeals a judgment convicting him of failing to provide his correct name, address, and date of birth, possession or distribution of dangerous knives, and refusing to submit to arrest; conviction followed a jury-waived trial.
During the February 2013 incident at Riverside Sports Pub, two men matched description were observed outside; Johnson provided ID and claimed identity inconsistently.
Officers discovered a knife and Johnson’s license after an officer-safety pat-down, and Johnson was identified as Erving M. Johnson.
Johnson moved to suppress the pat-down evidence; the suppression motion was denied, and the case proceeded to trial.
The court later acquitted Johnson of unlawful use of a license but convicted him on the remaining counts; the conviction for failing to provide his name, address, and birth date was later vacated on sufficiency grounds.
The court affirmed the three remaining convictions and noted the record does not indicate which system verified the name.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Confrontation Clause applicability at suppression hearing	Johnson argues officers’ testimony about Lever’s radio info violated Confrontation Clause.	State contends the testimony was non-hearsay and not testimonial.	No Confrontation Clause violation; testimony not hearsay.
Sufficiency of evidence for failing to provide correct name, address, or date of birth	Johnson contends insufficient evidence before and after search.	State argues there was probable cause after discovering Johnson’s license and knife.	Conviction vacated for insufficiency of evidence.
Consonance of suppression ruling with evidentiary rules	Not required to address beyond Confrontation Clause issue.	Suppression ruling stands independent of later sufficiency ruling.	Affirmed other aspects; suppression issue resolved on Confrontation Clause grounds.

State v. Tayman, 2008 ME 177 (Me. 2008) (Confrontation Clause applies to testimonial statements; not hearsay in context of probable cause)
State v. Vaughan, 2009 ME 63 (Me. 2009) (Hearsay; statements offered to show probable cause or articulable suspicion not for truth)
State v. Poole, 551 A.2d 108 (Me. 1988) (Hearsay and exceptions; probable cause/suspicion framework)
State v. Woodbury, 2011 ME 25 (Me. 2011) (Confrontation Clause; de novo review of constitutional issue)
State v. Smen, 2006 ME 40 (Me. 2006) (Sufficiency of evidence standard beyond reasonable doubt)
Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (Testimonial statements; Confrontation Clause scope)