Aaron Michael Lewis, Appellant v. State of Arkansas, Appellee

Summary

The court affirmed Lewis’s convictions and the denial of his suppression motions, holding that the officer’s encounter after Lewis’s vehicle crash was a permissible investigative encounter, that the victim’s voice recording was admissible, that Lewis lacked standing to challenge subpoenas issued to third parties, and that the vehicle inventory search was valid. The court also held that Lewis’s unpreserved challenge to alleged promises of leniency could not be considered. The State’s cross-appeal was dismissed as untimely because it challenged matters that could have been appealed from the original sentencing order. Justice Hart, concurring, agreed with admitting the recording but would have relied on the recording’s spontaneous, noncoerced disclosure rather than adopting the federal rationale applied by the majority.