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342 Ark. 151

28 S.W.3d 260

Stephens v. State

Supreme Court of Arkansas

Decided September 28, 2000

Supreme Court of Arkansas · decided 2000-09-28

Relies on Mings v. State · Hines v. State · State v. Sullivan

Good law ✅— No negative treatment on recordhow we know

Decided 2000-09-28

How this case has been cited

Cited by 31 later decisions — most recently September 2021 · most notably Barnes v. State (2001), State v. Sullivan (2002)

31 state decisions

230200020102020decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

View the full empirical analysis of this case →

Robert L. Brown, Justice,

¶1concurring. I agree with the majority opinion but write only to expand on one point. The majority opinion correctly cites Mings v. State, 318 Ark. 201, 884 S.W.2d 596 (1994), for the following proposition:

An ulterior motive does not in itself render an arrest pretextual when there is a valid overt reason to make the arrest. Id. (citing Hines v. State, 289 Ark. 50, 55, 709 S.W.2d 65, 68 (1986)). The reasoning is that the arrest for the overt violation would have taken place in any event; thus there is no reason to bring the Fourth Amendment and the exclusionary doctrine-into play. Id.

¶2The Mings opinion, however, goes forward and emphasizes that an objective, reasonable-officer standard is applied in determining whether the arrest is valid and relies on Wayne R. LaFave’s distinguished treatise as authority. See 1 Wayne R. LaFave, Search and Seizure § 1.4, at 22 (Supp. 1994). Thus, failure to meet the objective and reasonableness standard set out in Mings can undermine the validity of an arrest. We recently upheld a reasonableness standard for pretextual arrests in State v. Sullivan, 340 Ark. 315, 11 S.W.3d 526 (2000), reh’g denied 340 Ark. 318-A, 16 S.W.3d 551 (2000).

Smith, J., joins.
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