Robinson v. State
2014 Ark. 101
| Ark. | 2014Background
- Robinson was stopped by Trooper Outlaw for a defective taillight on a Ford pickup on Highway 278.
- The taillight allegedly displayed both white and red light due to a cracked lens.
- The stop led to Robinson’s DWI-related charges and other offenses; some charges were dismissed after suppression issues.
- Circuit court denied the motion to suppress, finding probable cause to stop based on defective taillight.
- Robinson argued no probable cause existed because there is no Arkansas statute prohibiting a cracked taillight, and thus no traffic offense.
- Appellate review affirms the circuit court, holding probable cause existed based on the taillight’s condition.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a partially broken taillight creating white and red light supports probable cause | Robinson | State | Probable cause affirmed; stop valid. |
Key Cases Cited
- Malone v. State, 364 Ark. 256, 217 S.W.3d 810 (2005) (taillight defect supported stop; no illegality in initial stop)
- Sims v. State, 356 Ark. 507, 157 S.W.3d 530 (2004) (taillight/brake-light failure supports stop)
- State v. Harmon, 353 Ark. 568, 113 S.W.3d 75 (2003) (pretextual stop for broken light upheld)
- Burris v. State, 330 Ark. 66, 954 S.W.2d 209 (1997) (taillight lens partially broken; white light not red; prob. cause)
- Enzor v. State, 262 Ark. 545, 559 S.W.2d 148 (1977) (stop lawful where brake light not operative)
- Hileman v. State, 259 Ark. 567, 535 S.W.2d 56 (1976) (nonworking brake lights support stop)
- Travis v. State, 381 Ark. 7, 959 S.W.2d 32 (1998) (probable cause standard; less proof than conviction)
- Laime v. State, 347 Ark. 142, 60 S.W.3d 464 (2001) (probable cause; liberal review)
- Burks v. State, 362 Ark. 558, 210 S.W.3d 62 (2005) (probable cause to stop; officer’s view)