ME: Inevitable discovery doctrine doesn’t provide an incentive for police misconduct

The drugs here would have been inevitably found one way or the other. The inevitable discovery rule doesn’t provide the police an incentive to not comply with Fourth Amendment protections. State v. Prinkleton, 2018 ME 16, 2018 Me. LEXIS 15 (Jan. 25, 2018):

2. The Application of the Inevitable Discovery Doctrine Neither Provides an Incentive for Police Misconduct Nor Significantly Weakens Fourth Amendment Protections

[¶28] Applying the inevitable discovery doctrine to the facts presented here does not provide an incentive for police to make warrantless entries into any residence when they have probable cause to believe that there is drug-related activity therein. The record establishes that, after stopping the vehicle and corroborating the anonymous tip, the police intended to obtain a search warrant, and that, after consulting with their supervisors and an assistant attorney general, they decided to secure Taylor’s apartment before the search warrant was issued.

[¶29] The careful and deliberate actions that the motion court found the police had taken in this case support the motion court’s conclusion that the officers had a good faith belief that they had probable cause that there was ongoing criminal activity in Taylor’s apartment and that there were exigent circumstances justifying their entry to secure the apartment. There is no indication in the record that the police were attempting to subvert the Fourth Amendment warrant requirement. Furthermore, after entering the apartment, the police limited the scope of their search to patting down the occupants of the apartment for officer safety purposes. They did not search the residence until the search warrant was issued.

[¶30] Because the court did not err by finding that the police inevitably would have discovered the drug evidence by lawful means, and because, under the circumstances presented here, the application of the inevitable discovery doctrine does not create an incentive for police misconduct and does not significantly weaken Fourth Amendment protections, the motion court did not err in denying the motion to suppress.