Wilson v. State
2014 Ark. 8
| Ark. | 2014Background
- Wilson challenged suppression of cocaine obtained from a vehicle stop and GPS monitoring; circuit court denied suppression; Wilson pled guilty conditioned on appeal; issue raised: GPS device on rental car and subsequent search violated rights; vehicle rental and authorized-driver status at issue; owner of rental car was Enterprise; McClendon placed GPS device before Jones decision; court considered standing and reasonableness of detention and search.
- Vehicle driven by Wilson was a rental not in his name; Williams rented car to Wilson but contract designated Williams as only authorized driver; later contract renewal unclear; Wilson had no standing to challenge GPS search due to lack of legitimate expectation of privacy.
- Law enforcement used consensual search of vehicle after Wilson consented; drug dog was deployed after initial search; dog alert led to cocaine discovery; suppression denied.
- State argued Wilson lacked standing to challenge the search; Wilson argued detention after initial stop was unlawful and search invalid.
- Court held: (1) Wilson lacked standing to challenge the GPS search of the rental car; (2) Wilson had standing to challenge his detention as a vehicle occupant; (3) the prolonged detention was reasonable and not in violation of Rule 3.1; (4) timeline and diligent canine pursuit supported the denial of suppression.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing to challenge the search | Wilson had permission to use car | Enterprise contract restricted authorized drivers to Williams | Wilson lacked standing to challenge search |
| Reasonableness of continued detention | Detention exceeded permissible time after initial stop | Dog delay was reasonable and diligence shown | Detention reasonable under Rule 3.1 |
| GPS device as search under Jones | GPS placement violated Fourth Amendment | Jones controls but standing bars warrant analysis | Jones not controlling due to lack of standing; suppression denied |
Key Cases Cited
- Barter v. State, 310 Ark. 94 (1992) (standing to challenge search when driver lacks possession)
- Littlepage v. State, 314 Ark. 361 (1993) (no reasonable expectation of privacy in rented-car search)
- Stokes v. State, 375 Ark. 394 (2009) (occupants may challenge seizure independently of owner)
- Menne v. State, 2012 Ark. 37 (2012) (Rule 3.1 detention duration; reasonable suspicion factors)
- Davis v. State, 351 Ark. 406 (2003) (totality of circumstances for reasonable suspicion)
- Grant v. State, 267 Ark. 50 (1979) (consent to search; voluntary; not exceeding scope)
- United States v. Bloomfield, 40 F.3d 910 (8th Cir. 1994) (time reasonable to obtain drug dog; diligence)
- Jones v. United States, 132 S. Ct. 945 (2012) (GPS device constitutes a search; standing analysis not addressed)