State v. LaForge, 43 A.3d 961

Officer followed LaForge for about four miles on Eagle Lake Road in Bar Harbor under good weather and visibility.
The road is winding and has hills; there was no other traffic during the observation period.
Six line-violations were observed in three clusters: centerline straddling, crossing the fog line, and tire crossings of centerline/fog line.
Stop occurred after four miles solely based on the observed line-violations, with no speed or other indicators of impairment cited.
Motion to suppress the stop was granted; the State appealed; the appellate court vacated and remanded for denial of the motion to suppress.
Facts are accepted as found by the district court and reviewed for clear error; legal question is whether the stop was supported by objectively reasonable suspicion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the stop supported by objectively reasonable suspicion?	LaForge	LaForge	Yes; observations established reasonable suspicion.
What standard governs reviewing the stop’s legality?	State	LaForge	Legal de novo review with deferential factual findings.

State v. Pelletier, 541 A.2d 1296 (Me. 1988) (multiple erratic driving observations supported stop)
State v. Porter, 960 A.2d 321 (Me. 2008) (drive onto fog line and centerline within a short span justified stop)
State v. Cusack, 649 A.2d 16 (Me. 1994) (Fourth Amendment protections for vehicle stops)
State v. King, 965 A.2d 52 (Me. 2009) (de novo review of reasonable suspicion issue)
State v. Sylvain, 814 A.2d 984 (Me. 2003) (suspicion need only be more than a hunch)
State v. Caron, 534 A.2d 978 (Me. 1987) (single centerline straddle insufficient to stop)