Franklin v. State
In Franklin v. State, 60 Ark. App. 198, 962 S.W.2d 370, 373 (ArkCtApp 1998), the Arkansas court reversed a conviction for maintaining a drug premises.
In that case the defendant shared a house with another occupant. The police found cocaine under the carpet in a bedroom and under a doghouse in the backyard.
However, that defendant did not use the bedroom involved, and he was asleep in a different room when the police found the cocaine.
Furthermore, that defendant was afraid of the dogs. Finally, the Arkansas Court noted that no drugs were found in plain view or in the common areas of the house. 962 S.W.2d at 373.