Supreme Court of Arkansas

Isaac Elisha Evans, Appellant v. State of Arkansas, Appellee

February 19, 20152015 Ark. LEXIS 67

Summary

The court held that police lacked a reasonable basis under the Fourth Amendment to enter Evans's motel room to execute an arrest warrant because the entry rested solely on an uncorroborated anonymous tip that did not establish either that Evans resided in the room or that he was present. The court nevertheless affirmed because, after excluding the seized evidence, the remaining identification and surveillance evidence established guilt overwhelmingly and rendered the suppression error harmless beyond a reasonable doubt. Chief Justice Hannah, concurring, would have confined the analysis to the governing arrest-entry standard, while Justice Goodson, concurring, emphasized that the court did not equate that standard with reasonable suspicion.