Schneider v. State

2015 Ark. 152 (2015) · Supreme Court of Arkansas · April 9, 2015 · No. CR-14-1104

Summary

The Arkansas Supreme Court reviewed Jordan Arie Schneider’s conditional guilty plea and held that a vehicle-color discrepancy, without additional evidence of criminal activity, did not create reasonable suspicion sufficient to justify a traffic stop. The court reversed and remanded the sentencing order and vacated the Arkansas Court of Appeals opinion.

Holdings

  1. A discrepancy between the observed color of a vehicle and the color listed on its registration, standing alone, does not create reasonable suspicion of criminal activity sufficient to justify a traffic stop when the record contains no evidence that the discrepancy is indicative of criminal conduct.
  2. Because the traffic stop was not supported by reasonable suspicion, the circuit court erred by denying Schneider's motion to suppress.

Questions Presented

  1. Whether a discrepancy between a vehicle's observed color and the color listed on its registration, standing alone and without evidence connecting the discrepancy to criminal activity, creates reasonable suspicion sufficient to justify a traffic stop under Arkansas law.
  2. Whether the circuit court erred in denying Schneider's motion to suppress evidence seized as a result of the stop.

Disposition

reversed_and_remanded

Cases Cited (11)

  • Schneider v. State, 2014 Ark. App. 711, 492 S.W.3d 601(vacated)
  • Fowler v. State, 2010 Ark. 431, 371 S.W.3d 677(followed)
  • Pickering v. State, 2012 Ark. 280, 412 S.W.3d 143(followed)
  • Menne v. State, 2012 Ark. 37, 386 S.W.3d 451(followed)
  • Malone v. State, 364 Ark. 256, 263, 217 S.W.3d 810, 814 (2005)(followed)
  • Van Teamer v. State, 108 So. 3d 664 (Fla. App. Dist. 2013)(persuasive)
  • United States v. Uribe, 709 F.3d 646 (7th Cir. 2013)(persuasive)
  • Andrews v. State, 658 S.E.2d 126 (Ga. Ct. App. 2008)(distinguished)
  • Smith v. State, 713 N.E.2d 338 (Ind. App. 1999)(distinguished)
  • State v. Teamer, 151 So. 3d 421, 427 (Fla. 2014)(persuasive)

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Cited In (0)

No citing cases on record yet.

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