Supreme Court of Arkansas
Adam Eugene Lane, Appellant v. State of Arkansas, Appellee
February 16, 20172017 Ark. LEXIS 33
Summary
The court affirmed Lane’s convictions and the denial of his motions to suppress and in limine. It held that officers lawfully entered his hotel room under his parole search conditions and reasonable grounds to investigate parole violations, but violated the knock-and-announce requirement by entering without warning and without exigent circumstances. The court nevertheless held that suppression was not an appropriate remedy for that violation and that Lane’s affidavit was admissible because it was not an offer to plead guilty, while his alternative evidentiary arguments were unpreserved. Justice Womack, concurring, would have held that Lane’s parole status eliminated the knock-and-announce requirement altogether.