State v. Robinson
2013 Ark. 425
| Ark. | 2013Background
- Sherwood PD investigated a July 4, 2011 armed robbery in Sherwood and obtained both a search warrant and an arrest warrant for Kendrick Robinson on July 6, 2011.
- Sherwood officers executed the warrants at Robinson’s residence outside Sherwood city limits (an unincorporated area of Pulaski County); Robinson was arrested and officers seized a rifle, ammunition, clothing, and other items.
- Robinson moved to suppress evidence, arguing Sherwood officers acted outside their territorial jurisdiction and there was no interagency agreement or cooperation with local law enforcement.
- The Pulaski County Circuit Court granted the suppression motion, finding extraterritorial execution without interagency cooperation per se unreasonable under the Fourth Amendment.
- The State appealed interlocutorily; this Court reviewed whether the suppression ruling rested on a correct legal interpretation of rules/statutes and prior case law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the State’s interlocutory appeal is proper under Ark. R. App. P. — Crim. Rule 3 (jurisdiction) | The State: appeal presents a purely legal issue (undisputed facts) important to uniform administration | Robinson: appeal raises application-specific or factual matters not warranting State appeal | Majority: proper State appeal because material facts are undisputed and issue is legal; dissent would dismiss for lack of Rule 3 jurisdiction |
| Whether execution of a valid search warrant outside issuing municipality without interagency agreement is per se unreasonable and requires suppression | State: no bright-line rule requires interagency cooperation; statutes and Ark. R. Crim. P. 13.3 allow any officer to execute a warrant; totality-of-the-circumstances governs reasonableness | Robinson: Sherwood officers lacked territorial authority absent interagency agreement or local officers present; Fountain supports suppression | Majority: circuit court erred; no statutory/rule bright-line requiring interagency cooperation; under totality, execution was not per se unreasonable — reversed and remanded |
| Whether evidence could be justified as search incident to arrest (alternative State argument) | State: seizure valid as search incident to lawful arrest | Robinson: circuit court found search preceded arrest; evidence not admissible as incident to arrest | Majority: unnecessary to resolve after reversing on primary ground; circuit court’s alternative not addressed further |
Key Cases Cited
- State v. Fountain, 350 Ark. 437, 88 S.W.3d 411 (Ark. 2002) (relying on totality of circumstances when out-of-jurisdiction officers executed a search warrant)
- Colston v. State, 346 Ark. 503, 58 S.W.3d 375 (Ark. 2001) (discussing territorial jurisdiction norms for local peace officers)
- Logan v. State, 264 Ark. 920, 576 S.W.2d 203 (Ark. 1979) (territorial jurisdiction precedent referenced in later rulings)
- Brenk v. State, 311 Ark. 579, 847 S.W.2d 1 (Ark. 1993) (interpreting authority of judicial officers to issue search warrants statewide)
- Skinner v. Ry. Labor Executives’ Ass’n, 489 U.S. 602 (U.S. 1989) (Fourth Amendment reasonableness depends on totality of circumstances)
- United States v. Montoya de Hernandez, 473 U.S. 531 (U.S. 1985) (reasonableness judged by circumstances surrounding search or seizure)
- Delaware v. Prouse, 440 U.S. 648 (U.S. 1979) (balancing intrusion against governmental interests for Fourth Amendment analysis)