## Facts

- Thomas captained the fishing vessel *Blue Water*.
- The *Blue Water* held both a federal fishing license and a Maine commercial fishing license.
- While the *Blue Water* was fishing in the federal Exclusive Economic Zone (EEZ), Maine Marine Patrol officers boarded the vessel to conduct a search/inspection.
- During the boarding, officers found lobsters that exceeded the maximum size allowed under Maine law.
- The State charged Thomas with violating Maine’s lobster laws.
- Thomas moved to suppress the lobster evidence, arguing the officers lacked legal justification and jurisdiction to search the vessel while it was in the EEZ.
- The trial court denied the motion to suppress; Thomas was convicted and fined.
- Thomas appealed to the Maine Supreme Judicial Court (Law Court), again arguing that Maine officers lacked jurisdiction to search the vessel in the federal EEZ.

## Issues

1. Whether Maine Marine Patrol officers had authority to board and inspect a Maine-licensed commercial fishing vessel while it was operating in the federal EEZ to enforce Maine lobster restrictions.
2. Whether federal fisheries law displaced Maine’s ability to enforce its lobster laws against a Maine-licensed vessel in the EEZ.
3. Whether the warrantless boarding and inspection was a reasonable regulatory search such that the seized oversized-lobster evidence could be used in the state prosecution.

## Decision

- The Law Court affirmed the conviction and the denial of Thomas’s motion to suppress.
- The court held that Maine could enforce its lobster conservation requirements against a vessel holding a Maine commercial fishing license even when the vessel was operating in the federal EEZ, so long as the state requirements did not conflict with federal management.
- The court concluded that the Marine Patrol boarding and inspection fit within Maine’s regulatory enforcement authority for commercial fisheries and was constitutionally reasonable under the regulatory-search framework.
- Because the boarding was lawful, the oversized-lobster evidence was properly admitted.

## Legal Principles

- A state may enforce its fisheries conservation laws against vessels that hold the state’s commercial fishing license while those vessels operate outside state waters, including in the federal EEZ, when state enforcement does not conflict with federal fisheries regulation.
- Federal regulation of fisheries in the EEZ does not automatically bar all state enforcement; displacement generally requires a direct conflict or interference with federal rules or objectives.
- In closely regulated commercial fisheries, a warrantless boarding limited to compliance inspection may be reasonable when carried out under statutory authority tied to regulatory enforcement rather than general crime control.
- When a suppression motion turns on factual findings about licensing status, location, and the nature of the inspection, appellate review gives weight to supported trial-court findings.

## Conclusion

In *State of Maine v. Thomas*, the Law Court upheld Maine’s enforcement of its lobster-size restrictions against the captain of a Maine-licensed vessel operating in the federal EEZ and held that the Marine Patrol’s warrantless compliance boarding was a valid regulatory inspection, making the oversized-lobster evidence admissible and leaving the conviction and fine in place.


State of Maine v. Thomas, 8 A.3d 638 (2010)