State v. McPartland, 2012 ME 12

Old Town Police conducted a sobriety checkpoint on Stillwater Avenue from about 9:00 p.m. to 3:00 a.m.
Officer McAvoy encountered Mallory McPartland at the checkpoint after a speeding approach observed by McAvoy.
McPartland admitted consuming a martini around 10:00 p.m. prior to the checkpoint.
The suppression court held that the combination of admission and speeding created reasonable suspicion of impairment justifying secondary screening.
Appellant challenged only the sufficiency of justification for secondary screening; the roadblock itself was not challenged.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is there reasonable articulable suspicion for secondary screening?	McPartland: admission alone insufficient to justify secondary screening.	McPartland argued that nighttime context and speed support suspicion.	Yes; totality of circumstances supports reasonable suspicion.
What standard governs referrals to secondary screening at an OUI roadblock?	McPartland contends the wrong standard was applied.	State applies reasonable articulable suspicion to refer to secondary screening.	Reasonable articulable suspicion standard applies; referral supported.

Michigan Dept. of State Police v. Sitz, 496 U.S. 444 (U.S. 1990) (initial stop valid; extended questioning requires suspicion)
State v. Sylvain, 814 A.2d 984 (Me. 2008) (two-step framework for police interrogation and detention)
State v. Kent, 15 A.3d 1286 (Me. 2011) (OUI roadblock vehicle diversion analyzed under reasonable suspicion)
State v. Leighton, 551 A.2d 116 (Me. 1988) (roadblock site mechanics and pull-out space)
State v. King, 965 A.2d 52 (Me. 2009) (reasonable articulable suspicion required for extended detention)