Supreme Court of Arkansas

David Laime and Jeanna Dodd v. State of Arkansas

December 6, 2001347 Ark. 142

Summary

The court affirmed the denial of Laime and Dodd's motion to suppress drug evidence and statements. It held that the initial traffic stop was supported by probable cause and that the trooper had reasonable suspicion to continue detaining them based on the totality of the circumstances, including inconsistent accounts, concealed criminal history, and escalating agitation. The court did not reach whether a dog alert alone established probable cause or whether the warrant affidavit violated Franks because the roadside search was independently permissible and the affidavit's alleged defects were immaterial. Justices Hannah and Thornton dissented, arguing that the continued detention and canine sniff rested on an unsupported hunch and violated constitutional protections.