State v. Crane
2014 Ark. 443
| Ark. | 2014Background
- On Oct. 25, 2012, officers arrested Robert Martin after finding a large quantity of meth in his vehicle; Martin identified Stephen Crane as a buyer and allowed officers to view Crane’s texts. Officers used Martin’s phone to arrange a controlled meeting with Crane.
- Crane arrived in his minivan, exited, and approached Martin’s vehicle; officers asked his name, took him into custody, and an officer performed a pat-down that yielded meth from Crane’s pocket.
- After arresting Crane, officers searched his minivan and found a locked fireproof safe containing $5,000, drug paraphernalia, a small baggie of suspected meth, and a .32-caliber pistol.
- Crane was charged with multiple drug and weapons offenses and moved to suppress all items and statements obtained as a result of the contact. At the suppression hearing, Agent Sells testified about observing the pat-down and seeing suspected meth recovered; he was the only witness.
- The circuit court granted Crane’s motion, suppressing both the pat-down evidence and the contents of the locked safe—reasoning the pat-down lacked sufficient corroborating officer testimony and that exigent circumstances were required to search the locked safe without a warrant. The State filed an interlocutory appeal.
- The Arkansas Supreme Court dismissed the State’s challenge to suppression of the pat-down evidence (factual/credibility finding) but reversed the circuit court on the safe-search ruling, holding the automobile exception requires probable cause, not a separate exigency finding, and remanded for the court to determine whether probable cause to search the safe existed independent of the suppressed pat-down evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Legality of the pat-down of Crane | State: pat-down justified by officers’ involvement after controlled meeting and Sells’s testimony showing contraband located | Crane: circuit court correctly found insufficient evidence/corroboration; suppression proper | Dismissed as improvidently appealable — circuit court’s credibility-based factual ruling stands (suppression of pat-down evidence affirmed) |
| Warrant requirement to open locked safe in vehicle | State: automobile exception permits warrantless search of vehicle and containers if probable cause exists; no separate exigency required | Crane: circuit court required exigent circumstances to search locked safe; suppression proper without warrant | Reversed and remanded — circuit court erred to require exigency; automobile exception needs probable cause only; on remand court must assess probable cause to search safe independent of suppressed pat-down evidence |
Key Cases Cited
- Carroll v. United States, 267 U.S. 132 (establishing automobile exception)
- United States v. Ross, 456 U.S. 798 (probable cause to search vehicle permits search of containers within)
- California v. Acevedo, 500 U.S. 565 (police may search containers in vehicle when probable cause exists)
- Maryland v. Dyson, 527 U.S. 465 (automobile exception has no separate exigency requirement)
- Pennsylvania v. Labron, 518 U.S. 938 (per curiam reaffirmation that probable cause suffices for vehicle searches)
- Smith v. State, 254 Ark. 538 (material-witness rule requiring state to produce material witnesses when confession challenged)