Jackson v. State
2013 Ark. 201
| Ark. | 2013Background
- Corporal Behnke stopped a rental truck on I-40 for improper lane change and following too close; Jackson was front-seat passenger.
- Behnke observed a road atlas and a suitcase in the backseat and learned Jackson rented the truck; rental contract dated Oct 22, 2010.
- Maysonet provided travel details; Behnke sequentially checked licenses, rental agreement, VIN, and then waited on ACIC criminal-history checks for one man.
- Behnke deployed K-9 Major after an alert, leading to a warrantless search that recovered four or five pounds of marijuana in a suitcase.
- Jackson was Mirandized at the jail; he made a roadside statement and later a custodial statement; suppression motion was denied for custodial statement but granted for the roadside statement.
- Jackson appealed; the Arkansas Court of Appeals affirmed; this Court granted review; the circuit court’s ruling denied suppression of the vehicle search and custodial statement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the detention after the stop ended violated Rule 3.1 | Jackson contends detention continued without reasonable suspicion after the stop’s purpose ended. | State argues stop ongoing because Behnke hadn’t completed checks; canine search justified by ongoing stop. | Denial of suppression affirmed; stop not concluded when K-9 deployed due to ongoing checks. |
| Whether the warrantless vehicle search was supported by probable cause from the canine alert | Jackson argues canine alert alone cannot establish probable cause; evidence insufficient. | State argues K-9 Major’s alert, with reliability, provides probable cause to search. | Search upheld; canine alert provided probable cause under controlling precedent and Harris. |
| Whether the custodial statement after an alleged Miranda violation was admissible | Jackson argues statements were tainted by an unwarned confession and fruit of the poisonous tree. | State contends Miranda warnings were effective for the custodial statement; Seibert distinction not met; Elstad controls. | Custodial statement admissible; warnings effective; not fruit of poisonous tree. |
Key Cases Cited
- Sims v. State, 356 Ark. 507 (2004) (permit routine detention during stop and post-stop questioning)
- Yarbrough v. State, 370 Ark. 31 (2007) (when stop ends and consent to search is requested)
- Lilley v. State, 362 Ark. 436 (2005) (handover of paperwork marks end of stop)
- Menne v. State, 2012 Ark. 37 (2012) (standard for continuing detention during a stop)
- Florida v. Harris, 133 S. Ct. 1050 (2013) (dog reliability can establish probable cause)
- Oregon v. Elstad, 470 U.S. 298 (1985) (taint analysis after unwarned statements; focus on voluntariness)