State v. Lagasse, 149 A.3d 1153

On Jan. 3, 2013 two masked men robbed a Caribou resident; one displayed a firearm. The victim later identified Eric Mowatt as one of the robbers but not the other.
Police arrested Mowatt; while jailed he confessed involvement and later identified Chad Lagasse as his accomplice, stating the robbery was to pay Lagasse’s drug debt.
Mowatt later reported seeing Lagasse on Jan. 19 in a silver Mazda with a transport plate and provided the plate number; investigators told local officers to arrest Lagasse if located and to seek a reasonable basis to stop the car. No arrest warrant was sought.
On Jan. 20 a Caribou officer followed a car matching the description; the car veered sharply right and changed lanes without signaling. The officer conducted a high‑risk felony stop, recognized Lagasse when he exited, and arrested him.
Pills were observed on or near Lagasse at arrest; Lagasse was indicted for aggravated trafficking and other counts. He moved to suppress the drug evidence, arguing lack of probable cause for warrantless arrest, unreliability of Mowatt’s ID, and that the traffic stop was pretextual and lacked reasonable articulable suspicion. The Superior Court denied the motion; Lagasse was convicted of aggravated trafficking.

Issue	Plaintiff's Argument (Lagasse)	Defendant's Argument (State)	Held
Probable cause for warrantless arrest	Mowatt’s identification was unreliable/un corroborated; officers lacked probable cause to arrest Lagasse	Mowatt was an accomplice‑witness whose admission and vehicle ID supplied probable cause; collective police knowledge counts	Court: Probable cause existed — Mowatt’s confession/identification was sufficiently reliable to justify arrest
Lawfulness of traffic stop (reasonable articulable suspicion)	Stop was pretextual and lacked reasonable suspicion; failure to signal was minor and not a legitimate basis	Officer observed a traffic violation (sharp veer/change of lanes without signaling); plus prior info gave reasonable suspicion	Court: Stop lawful — officer had reasonable articulable suspicion (and probable cause via collective information)

Maryland v. Pringle, 540 U.S. 366 (collective knowledge/probable cause principle)
State v. Parkinson, 389 A.2d 1 (Me. 1978) (probable cause definition and informant discussion)
State v. Johnson, 434 A.2d 532 (accomplice testimony can support conviction)
State v. Jewell, 285 A.2d 847 (uncorroborated accomplice testimony may sustain conviction)
State v. Sawyer, 314 A.2d 830 (inconsistencies in accomplice statements do not necessarily vitiate credibility)
State v. Rideout, 761 A.2d 288 (Me. 2000) (reasonable articulable suspicion required for vehicle stops)
State v. Menard, 822 A.2d 1143 (Me. 2003) (probable cause subsumes reasonable suspicion)