State of Maine v. Douglas E. Wilcox

Summary

The court affirmed Wilcox's OUI conviction after concluding that the officer lawfully detained him to investigate a reported vehicle collision and assess his safety. The corroborated anonymous tip, vehicle damage, and Wilcox's slurred speech supplied reasonable articulable suspicion for the detention and field sobriety testing, which the court held was not a search requiring consent. The court also declined to consider Wilcox's unpreserved argument under the Maine Constitution.