Aaron Michael Lewis, Appellant v. State of Arkansas, Appellee — Hart, J., Concurring

Summary

Justice Hart concurred in the refusal to suppress the voice recording but rejected the majority’s reliance on the federal rule concerning physical fruits of unwarned statements. She reasoned that Lewis had received Miranda warnings, had spontaneously directed deputies to the phone, and had not been pressured to reveal or play the recording. She would rely on existing Arkansas precedent concerning spontaneous statements and police misconduct rather than adopt a new rule under the Arkansas Constitution.