## Facts

- Police operated an OUI roadblock; Kershaw E. Powell turned around before reaching it.
- An officer pursued and stopped Powell, then arrested him for operating under the influence.
- A chemical test indicated Powell’s blood-alcohol concentration was at or above 0.08%.
- In the related criminal prosecution, the trial court suppressed all evidence obtained after the stop for lack of reasonable, articulable suspicion; that ruling was affirmed on appeal.
- Separately, the Secretary of State administratively suspended Powell’s driver’s license under 29 M.R.S.A. § 1311-A based on the arresting officer’s report and the chemical test result.
- At an administrative hearing, Powell challenged only probable cause and argued the criminal suppression ruling bound the agency and that the exclusionary rule barred use of the suppressed evidence; the hearing examiner upheld the suspension.
- The Superior Court vacated the suspension, concluding the Fourth Amendment exclusionary rule applies in administrative license suspension hearings and that the hearing examiner should have considered whether the evidence was constitutionally obtained.
- The Secretary of State appealed.

## Issues

1. Whether 29 M.R.S.A. § 1311-A authorizes or requires the hearing examiner to decide the constitutional validity of the traffic stop (including reasonable suspicion) in an administrative license suspension hearing.
2. Whether the Fourth Amendment exclusionary rule must be applied to administrative driver’s license suspension proceedings, barring reliance on evidence suppressed in a related criminal case.

## Decision

- The Law Court vacated the Superior Court’s judgment and remanded for entry of judgment affirming the Secretary of State’s suspension decision.
- The court held the statute does not permit the hearing examiner to adjudicate the constitutionality of the stop as part of the administrative hearing.
- The court declined to extend the federal Fourth Amendment exclusionary rule to administrative license suspension hearings.

## Legal Principles

- Administrative license suspension hearings under 29 M.R.S.A. § 1311-A are limited to issues specified by the statute; the legality of the initial stop under Fourth Amendment reasonable-suspicion standards is outside that scope.
- The exclusionary rule is a judicially created deterrent remedy primarily associated with criminal prosecutions and is not automatically applicable in civil or administrative proceedings.
- A criminal court’s suppression ruling does not control a separate, remedial administrative suspension proceeding governed by its own statutory purpose and limited hearing issues.
- In weighing deterrence benefits against public-safety and administrative costs, the court may decline to apply the exclusionary rule where incremental deterrence is minimal and the proceeding serves a remedial highway-safety function.

## Conclusion

The Maine Law Court held that administrative OUI-related license suspension hearings are confined to statutory questions and do not include litigation of the stop’s Fourth Amendment validity, and it further held that the exclusionary rule does not bar use of evidence in those administrative proceedings even if the same evidence was suppressed in a related criminal case.


Powell v. Sec'y of State, 614 A.2d 1303 (Me. 1992)