Minor Child v. State of Arkansas

2026 Ark. App. 93
CourtCourt of Appeals of Arkansas
DecidedFebruary 11, 2026
StatusPublished

This text of 2026 Ark. App. 93 (Minor Child v. State of Arkansas) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Minor Child v. State of Arkansas, 2026 Ark. App. 93 (Ark. Ct. App. 2026).

Opinion

Cite as 2026 Ark. App. 93 ARKANSAS COURT OF APPEALS DIVISION III No. CR-25-202

MINOR CHILD Opinion Delivered February 11, 2026

APPELLANT APPEAL FROM THE PULASKI COUNTY CIRCUIT COURT, TENTH V. DIVISION [NO. 60JV-24-328] STATE OF ARKANSAS APPELLEE HONORABLE SHANICE JOHNSON, JUDGE

AFFIRMED

WENDY SCHOLTENS WOOD, Judge

Minor Child (MC) appeals from the plea-disposition order wherein he conditionally

pled guilty to the charge of being a minor in possession of a handgun. He was adjudicated

delinquent and sentenced to the custody of the Division of Youth Services on September 3,

2024. On appeal, MC argues that the circuit court erred in denying his motion to suppress

evidence; therefore, he contends his plea-disposition order should be reversed. We affirm.

On the morning of April 13, 2024, Jacksonville police were called to a domestic

disturbance at MC’s mother’s home where shots had been fired. At the June 6 suppression

hearing, the State presented testimony from four Jacksonville police officers, all of whom

were wearing body cameras at the time of the incident. Video from three of the officers—

Officer Tamara Wilder, Officer Tyler Burke, and Sergeant Jordan Cline—was played for the court during the officers’ testimony. While the officers were waiting for a warrant to search

the home, MC arrived at the scene.

Officer Wilder said that MC had that “gun walk” and kept “holding his hand over

his pocket.” She testified that he held his hand in front of his pants and that every time an

officer would approach him, he would turn his body or “blade off from them,” which she

explained from her training are signs that a person has a weapon. She asked officers on the

scene to watch MC because he was “acting like” he had a gun. She said that she knew he

“was a kid” and was confident that he had a weapon on him because of his behavior and

body language—the way he walked, kept his hand on his pocket, and touched his waistband.

Officer Burke testified that he was keeping an eye on the situation because MC had

his hand “down beside his . . . waistband . . . . [a]nd then he was walking towards the back

of the police car that had someone in custody.” Officer Burke told everyone to get away from

the back of the vehicle, at which point MC’s uncle approached MC and “wrapped him up

and pushed him” away from the police car “toward the other side.” Officer Burke said that

he was suspicious of MC due to MC’s body language and demeanor. Officer Burke also said

that MC showed up on the scene and appeared agitated as he walked straight to the back of

the police car despite officers telling him to back away. He said MC’s hand was stiff as he

walked and was not “swaying” but remained straight by his side.

Officer Moody, who was in charge of the scene, testified that Officer Burke told him

to keep an eye on MC. He then saw MC holding his left arm down by his side as if he were

trying to cover something up and keeping his left side out of Officer Moody’s view as if he

2 were keeping something from being seen. He said he notified Sergeant Cline about the

situation, and they called MC over to Officer Moody’s patrol unit. Before patting MC down,

Officer Moody asked MC his age, and MC said he was sixteen. Officer Moody testified that

he then had reasonable suspicion to believe MC was committing a crime: possession of a

handgun by a minor. When he grabbed MC’s arm to put it on the hood of the car, the officer

felt a handgun in MC’s clothing. MC resisted Officer Moody, and the gun fell to the ground.

At the conclusion of the hearing, the circuit court denied MC’s motion to suppress.

The court found that under the totality of the circumstances, officers had a reasonable

suspicion that MC was carrying a weapon after observing his walk, demeanor, and body

language. The court found that they had reasonable suspicion to suspect he was committing

the crime of minor in possession of a handgun once they confirmed that MC was, in fact, a

minor. MC subsequently entered a conditional plea of guilty to being a minor in possession

of a handgun.

When a defendant pleads guilty to a charge, he or she waives the right to appeal that

conviction. Hill v. State, 81 Ark. App. 178, 182, 100 S.W.3d 84, 87 (2003). There is an

exception, however, when a conditional plea of guilty is premised on an appeal of the denial

of a suppression motion pursuant to Arkansas Rule of Criminal Procedure 24.3. Cartwright

v. State, 2017 Ark. App. 100, at 4, 514 S.W.3d 494, 497.1

1 The Arkansas Rules of Criminal Procedure apply to juvenile-delinquency proceedings. Ark. Code Ann. § 9-27-325(f) (Repl. 2020).

3 In reviewing the denial of a motion to suppress, we conduct a de novo review based

on the totality of the circumstances, reviewing findings of historical facts for clear error and

determining whether those facts give rise to reasonable suspicion or probable cause, giving

due weight to inferences drawn by the circuit court and proper deference to the circuit

court’s findings. Lee v. State, 2014 Ark. App. 691, at 3, 449 S.W.3d 709, 711. We will not

reverse the circuit court’s ruling unless it is clearly against the preponderance of the evidence.

Id., 449 S.W.3d at 711. We defer to the circuit court’s assessment of the credibility of

witnesses. Id., 449 S.W.3d at 711.

MC contends that the circuit court erred in denying his motion to suppress, arguing

that the officers did not have reasonable suspicion to conduct a pat-down search. Arkansas

Rule of Criminal Procedure 3.1 (2025) provides:

A law enforcement officer lawfully present in any place may, in the performance of his duties, stop and detain any person who he reasonably suspects is committing, has committed, or is about to commit (1) a felony, or (2) a misdemeanor involving danger or forcible injury to persons or of appropriation of or damage to property, if such action is reasonably necessary either to obtain or verify the identification of the person or to determine the lawfulness of his conduct.

Our criminal rules define “reasonable suspicion” as “a suspicion based on facts or

circumstances which of themselves do not give rise to the probable cause requisite to justify

a lawful arrest, but which give rise to more than a bare suspicion; that is, a suspicion that is

reasonable as opposed to an imaginary or purely conjectural suspicion.” Ark. R. Crim. P.

2.1. In determining whether an officer had reasonable suspicion, courts must recognize that,

“when used by trained law enforcement officers, objective facts, meaningless to the

4 untrained, can be combined with permissible deductions from such facts to form a legitimate

basis for suspicion of a particular person and for action on that suspicion.” Mosley v. State,

2009 Ark. App. 799, at 7, 370 S.W.3d 273, 277. Further, a suspect’s demeanor, gait,

manner, and apparent efforts to conceal an article are all grounds for reasonable suspicion.

Ark. Code Ann. § 16-81-203(1), (2) & (13) (Repl. 2005).

MC relies on Brazwell v. State, 354 Ark. 281, 119 S.W.3d 499 (2003), in which the

supreme court reversed a circuit court’s denial of a motion to suppress, holding that the

police did not have reasonable suspicion to detain Brazwell. In that case, Brazwell was present

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Related

Hill v. State
100 S.W.3d 84 (Court of Appeals of Arkansas, 2003)
Brazwell v. State
119 S.W.3d 499 (Supreme Court of Arkansas, 2003)
Lee v. State
2014 Ark. App. 691 (Court of Appeals of Arkansas, 2014)
Cartwright v. State
2017 Ark. App. 100 (Court of Appeals of Arkansas, 2017)
Mosley v. State
370 S.W.3d 273 (Court of Appeals of Arkansas, 2009)

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2026 Ark. App. 93, Counsel Stack Legal Research, https://law.counselstack.com/opinion/minor-child-v-state-of-arkansas-arkctapp-2026.