Sheridan v. State, 368 Ark. 510

Summary

The Supreme Court of Arkansas considered whether a sobriety checkpoint conducted by the Little Flock Police Department violated the Fourth Amendment because it lacked prior authorization from an elected public official. The court applied the Brown v. Texas balancing test and held that neither the Fourth Amendment nor Michigan Department of State Police v. Sitz requires authorization by an elected official. The court affirmed the denial of Sheridan's motion to suppress and affirmed his conviction and sentence.

Holdings

1. The Fourth Amendment does not require an elected public authority to authorize a sobriety checkpoint before it may lawfully be implemented.
2. The denial of Sheridan's motion to suppress was affirmed because his challenge rested solely on the absence of elected-official authorization, and that absence did not render the checkpoint unconstitutional.

Questions Presented

1. Whether the Fourth Amendment required an elected public official or authority to authorize the sobriety checkpoint before its implementation.
2. Whether the checkpoint was an unreasonable seizure under the Fourth Amendment because it lacked such advance authorization.
3. Whether Sheridan was entitled to withdraw his conditional guilty plea and suppress the evidence obtained at the checkpoint.

Disposition

affirmed