James v. State
2012 Ark. App. 118
| Ark. Ct. App. | 2012Background
- Appellant Pattie Jo James pleaded guilty conditionally to possession of methamphetamine with intent to deliver and possession of drug paraphernalia in Arkansas County.
- Circuit court denied motions to suppress an initial pre-Miranda statement and to suppress subsequent evidence seized.
- Special Investigator Chastain obtained information from informant Pike about meth distribution involving Misti O’Dell and another individual.
- Chastain confronted O’Dell and appellant at Ms. Snyder’s Almyra residence; appellant was moved to the rear of a vehicle and questioned without Miranda warnings.
- O’Dell admitted drugs were in the vehicle; a baggie, pipe, and other meth-related items were found during subsequent search.
- Appellant was arrested, given Miranda warnings later, and provided a more complete statement; the trial court’s rulings were appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Miranda custody and pre-arrest statement admissibility | James argues the initial statement was compelled without Miranda warnings. | James contends she was not in custody; interrogation was routine. | Initial statement suppressed; custody found for Miranda purposes. |
| Validity of stop/detention and suppression of evidence | The stop lacked reasonable suspicion and was unconstitutional. | Investigative stop was supported by reasonable suspicion from informant and circumstances. | Evidence from the stop upheld; suppression denied. |
Key Cases Cited
- California v. Beheler, 463 U.S. 1121 (1983) (custody triggers Miranda; totality of circumstances governs custody assessment)
- Berkemer v. McCarty, 468 U.S. 420 (1984) (custody determination depends on objective circumstances)
- Stansbury v. California, 512 U.S. 319 (1994) (custody assessment is objective, not subjective)
- Hall v. State, 361 Ark. 379 (2005) (Miranda custody analysis in Arkansas context)
- Conway v. State, 62 Ark. App. 125 (1998) (traffic-stop-like context versus investigative stop)
- Shelton v. State, 287 Ark. 322 (1985) (removal from place under control of police versus home entry)
- Davis v. State, 351 Ark. 406 (2003) (totality-of-circumstances approach to reasonable suspicion)
- Cortez, 449 U.S. 411 (1981) (whole picture of circumstances for reasonable suspicion)
- Arvizu, 534 U.S. 266 (2002) (reasonable suspicion requires specific, particularized reasons)