## Facts

- At about 11:00 p.m. on April 13, 1993, a South Paris police officer patrolled a new, dead-end residential development on Cobble Hill Road.
- The development was generally uninhabited during weekdays, and the officer was conducting directed patrols after property owners complained of recent vandalism.
- That night, there was no specific complaint, and the driver’s operation of the vehicle was otherwise unremarkable.
- The officer stopped David Dean’s vehicle based on Dean’s presence in that location at that time and the officer’s desire to determine why the occupants were there and to obtain identifying information.
- The stop led to evidence supporting an operating under the influence (OUI) charge.
- Dean entered a conditional guilty plea in the District Court, preserving his right to appeal the denial of his suppression motion.
- The Superior Court vacated the conviction, concluding the stop lacked reasonable suspicion; the State appealed.

## Issues

1. Whether an investigatory stop is supported by reasonable, articulable suspicion when a vehicle is encountered late at night in an uninhabited, dead-end development that has recently been the subject of vandalism complaints, despite no observed driving violation or specific complaint that night.
2. What weight may be given to location-based crime reports and the absence of an apparent legitimate reason for presence when assessing reasonable suspicion under the totality of the circumstances.

## Decision

- The Maine Supreme Judicial Court vacated the Superior Court’s order and reinstated the District Court’s judgment of conviction.
- The court held that, under the totality of the circumstances, the officer had reasonable, articulable suspicion of criminal activity to justify the stop.
- The court concluded the District Court’s finding of reasonable suspicion was not clearly erroneous, and the Superior Court erred by overturning it.

## Legal Principles

- An investigatory stop requires specific and articulable facts, together with rational inferences, that reasonably warrant the intrusion; the standard is less demanding than probable cause.
- Courts assess reasonable suspicion under the totality of the circumstances, not by isolating facts.
- Mere presence in a high-crime area, without more, does not justify a stop.
- Location reputation and recent, place-specific crime reports may be considered as articulable facts, but must be combined with additional circumstances.
- Late hour and presence in an uninhabited or unusual location, coupled with recent crime in that area, may collectively support reasonable suspicion.
- Appellate review gives deference to trial-court findings on reasonable suspicion unless clearly erroneous.

## Conclusion

The court upheld a brief investigatory stop where the officer relied on recent vandalism reports in a specific area, the late hour, and the uninhabited, dead-end character of the location, concluding these combined facts created reasonable suspicion even though the driver’s conduct was otherwise normal and no complaint had been made that night.


State v. Dean, 645 A.2d 634 (Me. 1994)