State v. Sullivan

Tom Glaze, Justice,

dissenting. I dissent. The majority opinion claims that this court has traditionally treated pretextual arrests differently than have federal courts. However, the cases cited in the majority opinion do not support this contention. The questions of pretext in a majority of these cases were in fact analyzed under the Fourth Amendment and federal law, not under Arkansas law. See Smith v. State, 265 Ark. 104, 576 S.W.2d 957 (1979); Brewer v. State, 271 Ark. 810, 611 S.W.2d 179 (1981); Richardson v. State, 288 Ark. 407, 706 S.W.2d 363 (1986); and Thomas v. State, 303 Ark. 210, 795 S.W.2d 917 (1990). In Hines v. State, 289 Ark. 50, 709 S.W.2d 65 (1986), as the majority notes, the court adopted a “but for” approach in evaluating claims of pretextual arrest; however, the majority fails to note that this approach was taken from a mixture of federal law and the Professor LaFave treatise, Criminal Procedure, not from Arkansas law or historical precedent. Ray v. State, 304 Ark. 489, 803 S.W.2d 894 (1991), did follow the “but for” approach, but in 1993 the court decided Brenk v. State, 311 Ark. 579, 847 S.W.2d 1 (1993), without using the “but for” approach, and instead cited to Richardson v. State, supra, a holding under federal analysis, for its precedent.

The majority opinion ignores the more recent holdings by this court regarding pretextual arrest. In Mings v. State, 318 Ark. 201, 884 S.W.2d 596 (1994), this court implicitly overruled Hines, supra, and the “but for” approach by applying an objective test used by the Eighth Circuit. The court stated “that an otherwise valid stop does not become unreasonable merely because the officer has intuitive suspicions that the occupants of the car are engaged in some sort of criminal activity.” Mings, supra, (quoting United States v. Cummins, 920 F.2d 498, 501 (8th Cir. 1990)). This standard was applied in the last case before this court on pretextual arrest prior to this appeal on remand. See Stephens v. State, 342 Ark. 151, 28 S.W.3d 260 (2000).

The majority claims that the line of cases described above is proof that this court’s pretextual analysis developed in a different direction than that of the Supreme Court. The majority points out that in Whren v. United States, 517 U.S. 806 (1996), Justice Scalia stated that the Court had decided on several previous occasions that an officer’s motive does not invalidate objectively reasonable behavior under the Fourth Amendment. Flowever, it is clear, and the majority opinion acknowledges this, that the Court did not directly address the issue of pretextual stops and arrests until Whren. Therefore, the Arkansas cases were not contrary to federal law until the holding in the instant case.

The majority further points out that Arkansas is not in “lockstep” with federal Fourth Amendment interpretation in other search and seizure contexts, specifically in the case of Griffin v. State, 347 Ark. 788, 67 S.W.3d 582 (2002). However, Griffin is distinguishable from the instant case in two fundamental aspects. First, the Supreme Court has not decided a “knock and talk” case, whereas Whren is a clear statement on pretextual stop and arrest. Second, this court and the Supreme Court have held that people have a lesser expectation of privacy in their vehicles than in their homes. See Cardwell v. Lewis, 417 U.S. 583 (1974); and Tackett v. State, 307 Ark. 520, 822 S.W.2d 834 (1992).

The majority opinion does not address that the holding in this case will overrule strong precedent that this court interprets Ark. Const. art. 2, § 15 in the same manner the Supreme Court interprets the Fourth Amendment to the Constitution of the United States. See Rainey v. Hartness, 339 Ark. 293, 5 S.W.3d 410 (1999); Fultz v. State, 333 Ark. 586, 972 S.W.2d 146 (1998); Mullinax v. State, 327 Ark. 41, 938 S.W.2d 801 (1997); and Stout v. State, 320 Ark. 522, 898 S.W.2d 457 (1995). There is a strong presumption that the court’s prior decisions are valid. See Ray v. State, 342 Ark. 180, 27 S.W.3d 384 (2000).

Further, the 'majority opinion does not address the fundamental facts of the case. Mr. Sulhvan was stopped for speeding and having an illegal tint on his windshield, two violations that he does not deny. Both of the violations occurred in front of a police officer, thus triggering Ark. R. Crim. P. 4.1(a)(iii), “A law enforcement officer may arrest a person without a warrant if the officer has reasonable cause to believe that such person has committed . . . (iii) any violation of law in the officer’s presence.” There is nothing in the law that requires the officer to fine, rather than arrest, Mr. Sullivan. The contraband was discovered in a vehicle search pursuant to Ark. R. Crim. P. 12.6(b), and the search was completed following the Conway Police Department’s Vehicle Inventory Policy. The stop, the arrest, and the search were ah valid. To hold otherwise creates a constitutional challenge in every case where Rule 4.1(a) (iii) is used by an officer to make a warrantless arrest.

In summary, the trial court should be reversed for three reasons. First, Arkansas follows the Supreme Court’s interpretation on search and seizure issues. Second, the current Arkansas law on this matter is the Mings objective standard. Third, there was a valid reason for the stop and for the arrest; therefore, the officer’s motivation is irrelevant under both Whren and Mings.

Imber, J., joins this dissent.