Prickett v. State
2016 Ark. App. 551
| Ark. Ct. App. | 2016Background
- On July 23, 2015, Monticello police Officer James Slaughter stopped Jimmy Lee Prickett and discovered methamphetamine and a firearm after Prickett consented to a vehicle search.
- Slaughter testified he stopped Prickett because he knew Prickett’s driver’s license was suspended, based on a radio report from two weeks earlier and a personal sighting the day before.
- Slaughter did not check dispatch to verify the suspension immediately before initiating the stop; he confirmed the suspension after telling Prickett he was under arrest.
- At the suppression hearing, Slaughter admitted he did not document his prior verifications in his report and acknowledged the sole reason for the stop was the suspended-license belief.
- The trial court denied Prickett’s motion to suppress; a jury convicted Prickett of possession of a controlled substance, simultaneous possession of drugs and firearms, and possession of a firearm by certain persons, and acquitted him of driving on a suspended license.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity of traffic stop — probable cause to stop for driving on a suspended license | Prickett: Officer lacked reasonable suspicion/probable cause because Slaughter did not verify suspension with dispatch before stopping him | State: Officer had reasonable cause based on two prior verifications (one the day before) and a recent radio report that Prickett’s license was suspended | Court held: Probable cause existed — the officer’s recent verifications supported a reasonable belief the license remained suspended, so the stop was lawful |
| Admissibility of evidence obtained during and after stop | Prickett: Evidence was fruit of an unlawful stop and should be suppressed | State: Because the stop was supported by probable cause, the subsequent consent search and evidence were admissible | Court held: Because the stop was lawful, denial of the motion to suppress was affirmed; evidence admissible |
Key Cases Cited
- Robinson v. State, 431 S.W.3d 877 (Ark. 2014) (defines probable cause for traffic stops and explains standard of review)
- Travis v. State, 959 S.W.2d 32 (Ark. 1998) (officer’s reasonable belief based on recent verification can support probable cause to stop)