People often ask how to interface with Bluetooth from J2ME.
Here's a simple tutorial link that I think is worth a look. It makes use of JSR-185 for accessing a Bluetooth GPS receiver. It does not use the Location API though, it (only ) accesses the Bluetooth device directly, then parses the NMEA data coming from it.
http://www.hcilab.org/documents/tutorials/BT_GPS/BT_GPS.htm