C. Williams v. State
2017 Ark. App. 291
| Ark. Ct. App. | 2017Background
- On August 29, 2014, Deputy Tony Ball saw Christopher Williams driving; Ball had stopped Williams about 2–4 weeks earlier and believed Williams’s license was suspended.
- Ball activated his lights and stopped Williams after Williams drove into his driveway; Ball then ran an ACIC check and confirmed the license suspension.
- Ball told Williams the car would be towed and asked for an inventory search; Williams consented to a search of the vehicle.
- Deputies recovered a taped package with a white crystalline substance, a glass pipe, and digital scales; laboratory testing showed 4.0969 grams of methamphetamine.
- Williams moved to suppress the evidence, arguing the initial traffic stop lacked reasonable suspicion/probable cause because Ball had not confirmed the suspension before stopping him; the trial court denied the motion, convicted Williams of possession with intent to deliver and possession of paraphernalia, and imposed probation.
Issues
| Issue | Williams' Argument | State's Argument | Held |
|---|---|---|---|
| Whether the traffic stop was lawful | Ball lacked reasonable suspicion/probable cause because he only suspected the license was suspended and could not recall dates | Ball had recent personal knowledge (2–4 weeks prior) that the license was suspended, and confirmed it during the stop | Stop was lawful; probable cause existed |
| Whether evidence should be suppressed as fruit of unlawful seizure | Evidence seized after an illegal stop must be suppressed | Stop was not illegal; consent and inventory search were valid, so evidence admissible | Suppression denied; evidence admissible |
| Whether officer credibility conflicts require reversal | Ball’s uncertainty about dates undermines his testimony | Trial court properly credited Ball’s testimony and inferences | Appellate court defers to trial court credibility findings |
| Standard for assessing probable cause based on prior knowledge | Old knowledge (weeks old) is stale and insufficient | “Freshness” (2–4 weeks) can support reasonable belief that suspension continued | Information was not stale; 2–4 weeks supported probable cause |
Key Cases Cited
- Lockhart v. State, 2017 Ark. 13, 508 S.W.3d 869 (probable cause required for traffic stop)
- Robinson v. State, 2014 Ark. 101, 431 S.W.3d 877 (probable-cause definition and liberal review)
- Prickett v. State, 2016 Ark. App. 551, 506 S.W.3d 870 (officer’s knowledge weeks earlier supports probable cause)
- Delaware v. Prouse, 440 U.S. 648 (state interest in licensed drivers is substantial)
- Terry v. Ohio, 392 U.S. 1 (reasonable articulable suspicion and investigatory stops)