Hinojosa v. State

Summary

The Supreme Court of Arkansas affirmed the denial of Martin Hinojosa's motion to suppress evidence obtained after a traffic stop. The court held that Arkansas Code section 27-14-716's license-plate display requirements apply to both resident and nonresident vehicles, and that the officer had probable cause to stop Hinojosa's vehicle because its frame obscured the issuing state's name. The court did not reach Hinojosa's argument that the stop was unlawfully prolonged because the issue had not been ruled on by the circuit court.

Holdings

1. The officer had probable cause to stop Hinojosa's vehicle because section 27-14-716 requires a license plate to be clearly visible and clearly legible and prohibits a cover that makes the plate more difficult to read; those requirements encompass the issuing state's name, not merely the registration numbers.
2. The license-plate display requirements in section 27-14-716 apply to all vehicles traveling on Arkansas roads, including resident and nonresident vehicles.
3. The court could not reach the merits of Hinojosa's argument that the stop was unlawfully prolonged because he failed to obtain a ruling on that argument in the circuit court.

Questions Presented

1. Whether the officer had probable cause to stop Hinojosa's vehicle under Arkansas Code Annotated section 27-14-716 when the license-plate frame obscured the issuing state's name.
2. Whether the license-plate display requirements of section 27-14-716 apply to vehicles registered in another state notwithstanding section 27-14-704.
3. Whether Hinojosa's argument that the stop was unlawfully prolonged was preserved for appellate review.

Disposition

affirmed