State v. Journet, 191 A.3d 1181

Police executed a search warrant at an Augusta residence and found illegal drugs; a resident (cooperating individual) identified his supplier as a black male known as "Troy," who would deliver ~10 grams of heroin that evening.
The cooperating individual produced text messages corroborating that the delivery was "good to go," and said the supplier would be driving a blue BMW SUV from the Portland area and often transported heroin in his pants.
Officers positioned around the neighborhood observed a blue BMW SUV with a black male driver and white passenger drive along a likely route from Portland and then turn onto the short dead‑end street by the residence.
The detective initiated a traffic stop as the blue BMW approached the residence; Journet (the driver) was ordered out, patted down, handcuffed, taken to the sheriff’s office, and later confessed; the passenger produced a baggie containing nearly ten grams of heroin.
Journet moved to suppress the heroin and his statements, arguing the warrantless arrest lacked probable cause; the motion court denied suppression, and the trial court accepted a conditional guilty plea to aggravated trafficking (Class A). The Maine Law Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers had probable cause to effect a warrantless arrest of Journet	Journet: officers lacked probable cause; arrest was unlawful so statements and evidence should be suppressed	State: collective, corroborated information (search results, tip, texts, vehicle/time/route match) gave probable cause to arrest for felony trafficking	Court held: probable cause existed based on the totality of corroborated information; suppression denied
Reliability of the cooperating individual/tip as basis for arrest	Journet: tipster was untested by police and therefore unreliable	State: tipster’s information was substantially corroborated (drugs at the house, texts, vehicle, timing, route), supplying sufficient indicia of reliability	Court held: corroboration rendered the tip reliable enough to support probable cause

State v. Kierstead, 114 A.3d 984 (Me. 2015) (standard for appellate review of motion‑to‑suppress findings when no request for further findings)
State v. Lagasse, 149 A.3d 1153 (Me. 2016) (probable cause standard for warrantless arrests; collective knowledge rule)
State v. Parkinson, 389 A.2d 1 (Me. 1978) (definition of probable cause)
Maryland v. Pringle, 540 U.S. 366 (U.S. 2003) (probable cause can be based on facts warranting belief a felony was committed by occupants of a vehicle)
State v. Carr, 704 A.2d 353 (Me. 1997) (collective information known to police may support probable cause)
State v. Enggass, 571 A.2d 823 (Me. 1990) (objective examination of facts known to officers for probable cause)
State v. Heald, 314 A.2d 820 (Me. 1973) (probable cause analysis framework)
State v. Violette, 138 A.3d 491 (Me. 2016) (reasonable suspicion standard for investigatory stops)
State v. Commeau, 852 A.2d 70 (Me. 2004) (tactical considerations about requesting further findings after an adverse ruling)