State v. Bell

In State v. Bell, 329 Ark. 422, 948 S.W.2d 557 (1997), the Court abandoned the bright-line rule for determining whether a statement to police officers must be suppressed because a person, under the Fourth Amendment, had been seized. Instead, the court stated: "Rather, we will view a verbal admonition of freedom to leave as one factor to be considered in our analysis of the total circumstances surrounding compliance with Rule 2.3. In short, when interpreting Rule 2.3 in the future in deciding whether a seizure of a person has transpired, we will follow United States v. Mendenhall, 446 U.S. 544, 100 S. Ct. 1870, 64 L. Ed. 2d 497 (1980). (Bell, 329 Ark. at 431, 948 S.W.2d at 562.)