ME: Officer’s crossing city limits in pursuit, even if a violation of statute, didn’t violate 4A

Even if the officer violated state law on his territorial jurisdiction, following defendant across the city limits into another town to make a traffic stop didn’t violate the Fourth Amendment and there is no reason to apply the exclusionary rule. State v. Turner, 2017 ME 185, 2017 Me. LEXIS 202 (Aug. 22, 2017, rev. Dec. 7. 2017):

[*P21] In the matter before us, the officer did not intentionally make an excursion into Waterville to ferret out crime; rather, he happened to observe a crime being committed while engaged in a lawful, extraterritorial traffic stop.See 30-A M.R.S. § 2671(2)(E). He also communicated his actions promptly enough that a Waterville officer arrived on the scene almost immediately. Furthermore, based on the officer’s observations of the driver striking the median and operating erratically, the officer could have reached several reasonable conclusions justifying the officer’s further investigation. For example, until the officer located the vehicle parked in the bank’s parking lot, the officer could have reasonably believed that the driver would continue to pose an imminent risk to public safety or was himself in some circumstance needing assistance. Until the officer checked the driver’s condition through personal contact, the officer could have been reasonably acting in his community caretaking capacity. Under all of these circumstances, the officer’s request for Turner’s license and registration during the very brief period between making contact with him and the arrival of the Waterville officer was not unreasonable.

[*P22] In sum, the Winslow officer’s action of pursuing an erratically operated vehicle was reasonable, as was his initial contact with the driver, and the officer did not intentionally disregard his territorial limits in an attempt to ferret out crime. The motion court did not err in denying Turner’s motion to suppress.