State v. Harmon

In State v. Harmon, 353 Ark. 568, 113 S.W.3d 75 (Ark. 2003), the Supreme Court of Arkansas, interpreting the Arkansas constitution, refused to apply its State v. Sullivan rationale to traffic stops (Sullivan involved a pretextual arrest, not a traffic stop), reasoning that a traffic stop does not present the heightened intrusiveness of an arrest. The court observed that "an otherwise valid stop does not become unreasonable merely because the officer has intuitive suspicions that the occupants of the car are engaged in some sort of criminal activity." Harmon, 113 S.W.3d at 79.