Stuart v. State, 2017 Ark. App. 356

On July 19, 2015, dispatch reported a reckless driver in a red Ford pickup on Highway 425; Officer James Slaughter located and followed a red pickup driven by Thomas Stuart.
Slaughter observed the pickup weave within its lane and momentarily cross into a turning lane at the intersection of Highways 425 and 278; he initiated a traffic stop.
Slaughter detected bloodshot, watery eyes and smelled alcohol; Stuart performed a portable breath test (PBT) and field-sobriety tests, which Slaughter said indicated intoxication.
Stuart refused a chemical breath test at the detention facility after signing the DWI rights form; he later admitted to two beers and reported a PBT result of .08 and .13 on cross-examination.
Stuart moved to suppress evidence as the traffic stop lacked probable cause; the circuit court denied the motion and convicted Stuart of DWI and refusal to submit to chemical test.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officer had probable cause to stop Stuart	Stuart: video shows normal driving; a single brief crossing into the turn lane did not justify stop	State: crossing into turn lane plus report of reckless driving and weaving provided probable cause for careless driving stop	Court: Denied suppression; probable cause existed based on report and officer observations

Sims v. State, 356 Ark. 507 (Ark. 2004) (probable cause required to make traffic stop)
Laime v. State, 347 Ark. 142 (Ark. 2001) (probable-cause review is liberal)
Travis v. State, 331 Ark. 7 (Ark. 1998) (officer need not be correct about violation; reasonable belief suffices)
Navarette v. California, 134 S. Ct. 1683 (U.S. 2014) (investigative stops may be based on information from others)
Dods v. State, 240 P.3d 1208 (Wyo. 2010) (single instance of lane crossing can constitute a violation depending on surrounding circumstances)