Meeks v. State
2016 Ark. App. 9
| Ark. Ct. App. | 2016Background
- Meeks pled guilty conditionally to DWI-First Offense under AR Rule Crim Proc 24.3.
- Officer Mercado observed a stationary Tahoe in Marvin’s IGA parking lot, with a vomiting passenger.
- Before stopping, Mercado did not signal or indicate to Meeks to remain; stop occurs as Meeks attempts to exit.
- Blue lights were activated only as Meeks began exiting the lot, with no observed traffic violations prior to the stop.
- Motion to suppress was denied; Meeks appealed challenging the stop as unlawful under the Fourth Amendment and Arkansas law.
- Court reverses and remands, finding the stop illegal and suppressible evidence must be excluded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the stop was a seizure under Rule 3.1. | Meeks argues no reasonable suspicion existed. | Mercado asserts all stops require reasonable suspicion. | Stop unconstitutional; no reasonable suspicion. |
| Whether the stop was justified by community-caretaking or emergency-aid. | No emergency or caretaker basis shown. | Stop justified by perceived need to assist the vomiting passenger. | Not justified by caretaker or emergency-aid exception. |
| Whether the seizure was unlawful and all evidence should be suppressed. | Evidence obtained from illegal seizure must be suppressed. | Evidence admissible absent valid seizure. | Reversed; suppression warranted; remand for proceedings consistent with opinion. |
Key Cases Cited
- Cockrell v. State, 2010 Ark. 258 (Ark. Sup. Ct. (2010)) (establishes seizure based on reasonable suspicion in encounters)
- Hammons v. State, 327 Ark. 520 (Ark. Sup. Ct. (1997)) (defines reasonable suspicion for traffic stops)
- Blakemore v. State, 25 Ark. App. 335 (Ark. App. Ct. (1988)) (community caretaking function allowed knocking and inquiry)
- Szabo v. State, 2015 Ark. App. 512 (Ark. App. Ct. (2015)) (limits caretaking to facts showing need for assistance)
- Andrews v. State, 79 S.W.3d 649 (Tex. Ct. App. (2002)) (four-factor framework for caretaking justification)
- Wright v. State, 18 S.W.3d 245 (Tex. Ct. App. (2000)) (stopping where no aid requested or needed invalidates caretaking stop)
- Winters v. Adams, 254 F.3d 758 (8th Cir. (2001)) (example of caretaking in intoxication/danger scenarios)
- Mincey v. Arizona, 437 U.S. 385 (U.S. (1978)) (emergency aid requires imminent danger or need for aid)
- Miller v. State, 2010 Ark. 1 (Ark. Sup. Ct. (2010)) (mechanism for evaluating emergency-aid exception)
- Whren v. United States, 517 U.S. 806 (U.S. (1996)) (probable cause to stop for traffic violation)
- Davis v. State, 351 Ark. 406 (Ark. Sup. Ct. (2003)) (authorization of seizures and searches under constitutional standards)
- State v. McFadden, 327 Ark. 16 (Ark. Sup. Ct. (1997)) (stop authority based on traffic violations)