Plotts v. State

In Plotts v. State, 297 Ark. 66, 759 S.W.2d 793 (1988), the supreme court listed the factors to be used to link an accused to contraband found in a car jointly occupied by more than one person. The court stated that the contraband must be: (1) in plain view; (2) on the defendant's person or with his personal effects; (3) found on the same side of the car seat as the defendant or in immediate proximity to him; or that the accused; (4) owned the vehicle in question or exercised dominion and control over it; (5) acted suspiciously before or during arrest.