Lee Roy Davis v. State of Arkansas

Summary

The Supreme Court of Arkansas affirmed the trial court's denial of Lee Roy Davis's motion to suppress a crack pipe and cocaine found during a pat-down search, and reversed the court of appeals' contrary decision. Clarifying its law, the court held that suppression rulings are reviewed de novo on the totality of the circumstances, with historical facts reviewed for clear error and due weight given to the trial court's inferences, displacing the former 'light most favorable to the State' phrasing. Applying that standard, the court held the officers had reasonable suspicion to stop Davis based on the high-crime location, the apparent hand-to-hand exchange, the men's quick separation, Davis's false name and birth date, and his nervous demeanor, and that the pat-down was justified under Terry and Rule 3.4. Justice Brown dissented, contending only pre-stop facts may count and no actual hand-to-hand exchange was observed; Justice Hannah dissented, agreeing the stop was valid but arguing the pat-down was an unlawful search for contraband begun before Davis reached for his pocket.