Arkansas v. Sullivan

A police officer stopped the defendant for speeding and for having an improperly tinted windshield. After a brief discussion with the defendant, the officer realized that he was aware of “intelligence on [the defendant] regarding narcotics.” The officer noticed a weapon when the defendant opened the car door in an (unsuccessful) attempt to locate his registration and insurance papers. He placed the defendant under arrest for speeding, driving without his registration and insurance documentation, carrying a weapon, and improper window tinting with the expectation of conducting an inventory search of the defendant’s vehicle. During an inventory of the vehicle’s contents, the officer discovered a controlled substance. The defendant moved to suppress this evidence on the grounds that the arrest was a pretext and sham to search.