Collins v. State
2014 Ark. App. 574
Ark. Ct. App.2014Background
- Collins appeals denial of motions to suppress evidence linked to a conditional plea on cocaine, paraphernalia, marijuana, and firearms charges.
- Police searched Collins's residence on December 6, 2012 pursuant to a search warrant; Collins arrived during the ongoing search.
- Officers questioned Collins on the porch; a patrol officer directed to hold him; Collins stayed without being told he could leave.
- Detective Welborn sought consent to search Collins's U-Haul storage units; no Miranda warnings given during transport to the facility.
- Collins signed a consent form for unit 600; warnings purportedly given later, but not properly documented.
- A second unit, 556, was also searched after Collins allegedly consented; drugs were found; Collins was handcuffed and taken to the station.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Miranda warnings were required before custodial questioning | Collins argues custodial interrogation without warnings violated rights. | State contends Collins was not in custody under totality of circumstances and volunteered information. | Not clearly erroneous; court found no custody for Miranda purposes. |
| Whether statements and evidence from the residence and U-Haul search were admissible | Collins asserts failure to warn invalidates statements and search-derived evidence. | State argues voluntary statements and consent to search negate suppression. | Affirmed; statements and searches upheld under totality of circumstances. |
| Whether consent to search storage units was voluntary | Collins contends consent was coerced; no freedom to leave regarding searches. | State maintains voluntary, informed consent; no duress or coercion. | Consent deemed voluntary; no suppression required. |
| Whether the fruit-of-the-poisonous-tree doctrine applies | Collins argues illegally obtained statements taint all subsequent evidence. | State asserts no Fourth Amendment violation underlying the searches. | Inapplicable; no Fourth Amendment violation identified to trigger fruit-of-the-poisonous-tree. |
Key Cases Cited
- Yarborough v. Alvarado, 541 U.S. 652 (U.S. 2004) (custody analysis under Miranda and objective circumstances)
- Rhode Island v. Innis, 446 U.S. 291 (U.S. 1980) (interrogation scope and functional equivalent)
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (mandatory warnings before custodial interrogation)
- Shelton v. State, 287 Ark. 322 (Ark. 1985) (custody and Miranda warnings failure reversible)
- Gardner v. State, 296 Ark. 41 (Ark. 1988) (custody determination via totality of circumstances)
- James v. State, 2012 Ark. App. 118 (Ark. App. 2012) (credibility and totality review framework)
- Davis v. State, 351 Ark. 406 (Ark. 2003) (standard for reviewing suppression rulings)
- Oregon v. Elstad, 470 U.S. 298 (U.S. 1985) (fruit-of-the-poisonous-tree distinction)
- Salinas v. Texas, 133 S. Ct. 2174 (U.S. 2013) (invoke privilege requirement and forfeiture rules)