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 unlawfully entered Evans's motel room to execute an arrest warrant because an uncorroborated anonymous tip, together with lights and a television being on, did not establish a reasonable belief that Evans resided there and was present. The resulting suppression error was harmless beyond a reasonable doubt because overwhelming independent evidence established Evans's identity as the robber. Justice Hannah, joined by Justice Danielson, and Justice Goodson concurred, agreeing with the result but addressing the proper analytical framework and the majority's use of anonymous-tip precedent.