AR: Talking about drug deal on phone in convenience store overheard by officer led to plain view

“Arkansas State Police Trooper Stephen Briggs was inside the Valero convenience store on Colonel Glenn Road in Little Rock to get something to drink when he overheard a man on his cell phone say that he had lost $3200. The man also asked, ‘what was he supposed to do, go back and get his dope?’ Briggs bought his drink and went back to his vehicle, and, based on what he had overheard, he decided to watch the man, who subsequently went outside and got into a white Cadillac DeVille.” The officer watched and another car pulled up and the two men looked in the trunk of the Cadillac. The officer looked in the window of the Cadillac and saw a baggie of likely meth. That was a valid plain view. Moody v. State, 2014 Ark. App. 618 (November 5, 2014).*

In a traffic stop, “The marijuana odor emanating from appellant and the vehicle, alone, provided reasonable suspicion to detain appellant to determine the lawfulness of his conduct, to search the vehicle, and to arrest him, depending on the circumstances.” Blair v. State, 2014 Ark. App. 623, 2014 Ark. App. LEXIS 901 (November 5, 2014).*