Rainey v. State
2017 Ark. App. 427
| Ark. Ct. App. | 2017Background
- Police stopped a vehicle driven by Elaine Meads (Rainey as passenger) after observing a failure to signal; officers also had an informant tip identifying Rainey as a passenger with narcotics in a rusted Buick LaSabre.
- During the stop, Rainey exited the passenger side and yelled that he had a warrant; officers handcuffed him and detained him in a patrol car for safety; no active warrant was found.
- Officers obtained what they testified was Meads’s consent to search the vehicle; under Rainey’s seat they recovered baggies of suspected cocaine, scales, and paraphernalia.
- Rainey was arrested, advised of Miranda rights, signed a waiver form, and signed a written statement saying the drugs were his.
- Rainey moved to suppress the physical evidence (arguing invalid stop/search, absence of consent, unreasonable detention/searches) and to suppress his statement (Miranda/fruit of poisonous tree). The trial court denied both motions; a jury convicted him of possession with intent to deliver and possession of paraphernalia; aggregate sentence 480 months.
Issues
| Issue | Plaintiff's Argument (Rainey) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Validity of traffic stop | Stop lacked probable cause; officer testimony not credible | Officer had probable cause: driver failed to signal; court may credit officer testimony | Stop was lawful; trial court did not clearly err in finding probable cause |
| Search of vehicle / consent | Meads did not consent; search therefore unlawful | Officers obtained Meads’s voluntary consent before/search during valid stop | Court found consent was given; search admissible |
| Continued detention / multiple searches | Continued detention and repeated searches lacked reasonable suspicion; canine/third search unreasonable | Officer had reasonable suspicion (Rainey’s exit, yelling about a warrant, informant tip, Meads’s statement about a bag) | Detention and continued searches were reasonable under totality of circumstances |
| Voluntariness of Miranda waiver and statement | Statement was fruit of illegal seizure/search and therefore involuntary/tainted | Rainey was advised of rights, signed waiver and statement voluntarily; no constitutional violations requiring suppression | Trial court’s denial of suppression of statement affirmed; waiver and confession voluntary |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda-rights and waiver framework)
- Yarbrough v. State, 370 Ark. 31 (2007) (standard of review for suppression rulings)
- Laime v. State, 347 Ark. 142 (2001) (probable-cause standard for traffic stops)
- Freeman v. State, 391 S.W.3d 682 (Ark. Ct. App. 2012) (consent-search principles during traffic stop)
- Mancia-Sandoval v. State, 361 S.W.3d 835 (Ark. 2010) (pretextual stops upheld if valid stop exists)
- Grillot v. State, 107 S.W.3d 136 (Ark. 2003) (standard for voluntariness of custodial statements)