Supreme Court of Arkansas
Isaac Elisha Evans, Appellant v. State of Arkansas, Appellee — Hannah, J., Concurring
February 19, 20152015 Ark. LEXIS 67
Summary
The concurrence agrees that officers violated the Fourth Amendment by entering Evans's motel room to execute an arrest warrant based only on an anonymous tip that did not establish a reasonable belief that he lived there or was present. It also agrees that the suppression error was harmless beyond a reasonable doubt because the remaining identification and eyewitness evidence overwhelmingly established guilt. The concurrence explains that the entry question should be resolved under the reasonable-belief standard governing arrest-warrant entries, not the reasonable-suspicion standard used for traffic stops. Justice Goodson, concurring, likewise agrees with the invalid-entry conclusion but would leave unresolved the precise level of proof required under the reasonable-belief standard.