Summary
The Arkansas Supreme Court held that law enforcement lacked reasonable suspicion to prolong Cainis Redmond MacKintrush’s detention after a traffic stop to conduct a canine sniff of his vehicle. The court reversed the denial of his motion to suppress, reversed his convictions and sentence, and remanded; it did not reach his challenge to the jury instruction.
Topics
Practice areas
Questions Presented
- Whether reasonable suspicion existed to justify detaining the defendant beyond the time necessary for the initial traffic stop to allow a canine sniff
- Whether the jury instruction constituted an improper comment on the evidence
Holdings
- The facts and circumstances did not give rise to more than a bare suspicion, and reasonable suspicion was lacking to justify the prolonged detention.
Key quotations
“it is impossible for a combination of wholly innocent factors to combine into a suspicious conglomeration unless there are concrete reasons for such an interpretation”
Factual background
Appellant picked up a package at the post office that emitted a strong scent of dryer sheets. The package was addressed to a different name and address. After picking up the package and signing for it under the addressee's name, appellant was pulled over for a traffic violation. After routine traffic stop tasks were completed, police detained him for 34 minutes waiting for a drug dog to arrive. The dog alerted and drugs were found in the vehicle.
Procedural history
Appellant appealed from Pulaski County Circuit Court sentencing order reflecting convictions for drug offenses. He argued the circuit court erred in denying his motion to suppress evidence obtained after a prolonged traffic stop without reasonable suspicion.