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Arkansas v. Sullivan

United States Supreme Court · 2001 · Criminal Procedure

Criminal ProcedureFourth AmendmentTraffic StopsPretextual ArrestsSearch and SeizureFourth Amendmentprobable causepretext

Facts

Officer Taylor stopped Sullivan for speeding and improper window tinting. During the stop, Taylor recognized Sullivan from narcotics intelligence, saw a rusted roofing hatchet on the floorboard when Sullivan opened the car door, and arrested him for speeding, lack of registration and insurance documentation, carrying a weapon, and improper window tinting. After Sullivan was placed in a squad car, Taylor conducted an inventory search under department policy and found suspected methamphetamine and drug paraphernalia under the armrest. Sullivan moved to suppress, arguing the arrest was a pretext and sham to search him in violation of the Fourth and Fourteenth Amendments.

Issue

Whether a custodial arrest supported by probable cause violates the Fourth Amendment because the officer had an improper subjective motive and used the arrest as a pretext to search for evidence of another crime. Also, whether a state court may interpret the United States Constitution more broadly than controlling United States Supreme Court precedent permits.

Rule

When an arrest or stop is supported by probable cause, an officer's subjective intentions do not invalidate it under ordinary Fourth Amendment analysis. A state court may impose greater restrictions on police activity as a matter of its own law, but it may not do so as a matter of federal constitutional law when the United States Supreme Court has declined to impose those restrictions.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Tulsa, Officer Nina Cole stops Devin Mercer after seeing him drive 12 miles per hour over the speed limit. Cole has also heard neighborhood rumors that Mercer sells fentanyl and decides to arrest him for the speeding offense so the car can later be searched under standard impound procedures.

If Mercer moves to suppress solely because the arrest was a pretext to investigate drugs, how should a court rule under the Fourth Amendment?

Explanation. The controlling rule is that subjective intentions play no role in ordinary probable-cause Fourth Amendment analysis. Here, the stop and arrest were supported by probable cause for speeding, so suppression cannot rest solely on the officer's ulterior narcotics motive. (Derived from Arkansas v. Sullivan (n.d.).)