State v. Martin, 2017 Ark. 64

On Oct. 27, 2014, Christopher Martin was charged with multiple misdemeanors (DWI, refusal of chemical test, possession of marijuana and paraphernalia, seat-belt violation, fleeing, driving on suspended license/no insurance).
At trial the State presented Trooper Jason Murphy as its only witness, who testified Martin drove slowly, without a seat belt, had bloodshot eyes, nearly struck a cruiser, exited his moving truck, ran when ordered to stop, was tased, and was found with two baggies of marijuana; Martin later declined chemical testing and admitted impairment and possession.
After the State rested, Martin moved for a directed verdict asserting he had been illegally arrested (relying on Fowler v. State) and that all evidence and statements flowing from the illegal arrest were inadmissible.
The circuit court granted the directed-verdict motion mid-trial, entered a judgment of not guilty on all charges, and excused the jury.
The State appealed only the legal question whether an illegal arrest required dismissal (i.e., whether acquittal was an appropriate remedy), not the underlying facts of probable cause.
The Arkansas Supreme Court dismissed the State's appeal, holding the acquittal operated as a final resolution on sufficiency of evidence once the contested evidence was excluded and thus is not reviewable without violating double jeopardy.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an illegal arrest required dismissal (acquittal) of charges	State: illegal-arrest ruling was an incorrect remedy; illegal arrest alone does not bar prosecution; court should reverse and remand for retrial	Martin: illegal arrest (per Fowler) tainted searches/statements; exclusion of that evidence leaves insufficient proof, so directed verdict/acquittal appropriate	Dismissed State appeal; the mid-trial directed verdict functioned as an acquittal based on excluded evidence and is not reviewable due to double jeopardy
Whether the State may appeal the circuit court’s acquittal here	State: may appeal legal error (relying on Richardson) and seek reversal/remand for retrial	Martin: appeal impermissible because acquittal is final even if premised on erroneous legal ruling	Appeal dismissed; courts cannot review an acquittal without putting defendant in double jeopardy; this appeal was not permitted under Rule 3

Sanabria v. United States, 437 U.S. 54 (Sup. Ct.) (an acquittal based on excluded evidence is final and bars retrial)
United States v. Scott, 437 U.S. 82 (Sup. Ct.) (acquittal’s essential character is not altered by erroneous legal rulings)
Lee v. United States, 432 U.S. 23 (Sup. Ct.) (an acquittal resolves factual elements of the offense)
United States v. Martin Linen Supply Co., 430 U.S. 564 (Sup. Ct.) (defining acquittal as resolution of factual elements)
Fong Foo v. United States, 369 U.S. 141 (Sup. Ct.) (acquittal is final even if based on egregious error)
Smith v. Massachusetts, 543 U.S. 462 (Sup. Ct.) (acquittal may rest on mistaken understanding of sufficiency of evidence)
Arizona v. Rumsey, 467 U.S. 203 (Sup. Ct.) (acquittal precludes retrial even if statute was misconstrued)