State of Arkansas, Appellant v. Stephen Michael Crane, Appellee

Summary

The court dismissed the State’s challenge to suppression of the evidence obtained during the pat-down because resolving that issue required review of case-specific facts and witness credibility, which is not proper on a State interlocutory appeal. It reversed and remanded the suppression ruling concerning the locked safe because the automobile exception requires probable cause but no separate showing of exigent circumstances. On remand, the circuit court must determine whether probable cause existed independently of the pat-down evidence.