In Miller v. City of Little Rock, 23 Ark. App. 91, 743 S.W.2d 9 (1988), the police had a warrant to search an employee's residence and found marijuana. He was charged with the manufacture and possession of a controlled substance and possession with intent to deliver. After an evidentiary hearing, the employee was terminated from his position as a city firefighter. In the subsequent criminal proceedings, the criminal court suppressed the evidence obtained pursuant to the search warrant, because it was not based upon probable cause. On appeal of the termination of his employment, the employee argued that the evidence excluded from the criminal case should also have been excluded in the termination appeal. The Arkansas court held that the marijuana, seized pursuant to a search warrant, was admissible in a judicial review of the administrative discharge of the employee, because the exclusionary rule did not apply to noncriminal proceedings.