Wright v. State
In Wright v. State, 327 Ark. 558, 940 S.W.2d 432 (1997), the supreme court's analysis of whether a stop was legal was based not on whether there was reasonable suspicion of any criminal activity, but whether the criminal activity was covered by Rule 3.1.
The court stated:
"We would also point out that Ark. Crim. P. 3.1 provides that a law enforcement officer lawfully present in any place may, in the performance of his duties, stop and detain any person whom he reasonably suspects is committing, has committed, or is about to commit a felony or misdemeanor involving danger of forcible injury to persons. While this court has not been called upon to decide if a possible DWI offense falls within the language of Rule 3.1, our Court of Appeals has held, and we believe correctly, that a DWI violation carries with it the danger of forcible injury to others. See Nottingham v. State, 29 Ark. App. 95, 778 S.W.2d 629 (1989)." (Wright, 327 Ark. at 562-63, 940 S.W.2d at 434.)