State v. Sprenger
2016 Ark. 177
| Ark. | 2016Background
- March 14, 2013: police executed search warrants at Jason Sprenger’s business and residence based on allegations from a November 19, 2012 forensic interview of a 15‑year‑old (J.M.).
- J.M. alleged Sprenger performed oral sex on her when she was 10–11 and took nude photos; the affidavits supporting the warrants omitted any dates for when the alleged conduct occurred.
- Forensic review of seized devices produced ten images of minors (ages alleged 10–16) none of which were of J.M.; Sprenger was charged with rape and possession of child pornography.
- Sprenger moved to suppress the images; the circuit court initially denied the motion but later granted it, finding the warrant affidavits deficient for failing to specify when the alleged acts occurred.
- The State filed an interlocutory appeal, arguing (1) timing is not essential to probable cause and (2) the good‑faith exception should save the search.
- The Arkansas Supreme Court considered whether the State’s interlocutory appeal was proper under Ark. R. App. P.–Crim. 3 and whether the matters raised required statewide legal interpretation.
Issues
| Issue | State's Argument | Sprenger's Argument | Held |
|---|---|---|---|
| Whether the State may bring an interlocutory appeal from an order suppressing evidence under Ark. R. App. P.–Crim. 3(a)(1) | Appeal proper because the question raised is legal (timing not essential to probable cause) | Appeal improper; the ruling turns on fact‑intensive application of warrant rules | Dismissed — State appeal improper; Rule 3 permits only narrow legal questions that affect uniform administration |
| Whether the good‑faith exception to the exclusionary rule makes the search admissible despite affidavit defects | Good‑faith reliance on the warrant renders suppression unwarranted | The good‑faith claim raises mixed law‑and‑fact issues and is not a proper basis for a State interlocutory appeal | Dismissed as improper for State appeal because it presents mixed question of law and fact and lacks statewide rule interpretation |
Key Cases Cited
- State v. Threadgill, 382 S.W.3d 657 (Ark. 2011) (limits circumstances under which State may take interlocutory appeals in criminal cases)
- State v. Tyson, 388 S.W.3d 1 (Ark. 2012) (explains Rule 3 appellate limits for State appeals)
- United States v. Grubbs, 547 U.S. 90 (2006) (probable‑cause and magistrate’s common‑sense determination regarding presence of contraband)
- State v. Hart, 952 S.W.2d 138 (Ark. 1997) (good‑faith exception involves mixed questions and is generally inappropriate for State interlocutory appeal)