Motion to Suppress Evidence Arkansas

When court reviews a trial court's denial of a motion to suppress, it makes an independent determination based on the totality of the circumstances, but will only reverse if the trial court's decision was clearly against the preponderance of the evidence. Hill v. State, 64 Ark. App. 31, 977 S.W.2d 234 (1998). A law-enforcement officer may arrest a person without a warrant if the officer has reasonable cause to believe that the person has committed a felony. Ark. R. Crim. P. 4.1(a)(i) (1999). Reasonable cause exists when "the facts and circumstances within the officers' collective knowledge, and of which they have reasonably trustworthy information, are sufficient in themselves to warrant in a man of reasonable caution the belief that an offense has been committed by the person to be arrested." Williams v. State, 321 Ark. 344, 902 S.W.2d 767 (1995). Reasonable cause to arrest without a warrant does not require the degree of proof sufficient to sustain a conviction, and, in assessing the existence of reasonable cause, the appellate court's review is liberal rather than strict. Hudson v. State, 316 Ark. 360, 872 S.W.2d 68 (1994). Directed-verdict motions are treated as challenges to the sufficiency of the evidence. Bennett v. State, 308 Ark. 393, 825 S.W.2d 560 (1992). Where the sufficiency of the evidence is challenged, the reviewing court considers only that evidence which supports the guilty verdict. Stipes v. State, 315 Ark. 719, 870 S.W.2d 388 (1994). The test is whether there is substantial evidence to support the verdict, and on appellate review, "it is only necessary for this court to ascertain that evidence which is most favorable to the State." Jameson v. State, 333 Ark. 128, 130, 970 S.W.2d 785 (1998). Substantial evidence is evidence of such certainty and precision as to compel a conclusion one way or another. Jenkins v. State, 60 Ark. App. 122, 959 S.W.2d 427 (1998).