SANTIAGO VASQUEZ, JR. v. STATE OF ARKANSAS

CourtSupreme Court of Arkansas
DecidedSeptember 25, 2025
DocketCR-24-374
StatusPublished

This text of SANTIAGO VASQUEZ, JR. v. STATE OF ARKANSAS (SANTIAGO VASQUEZ, JR. v. STATE OF ARKANSAS) is published on Counsel Stack Legal Research, covering Supreme Court of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
SANTIAGO VASQUEZ, JR. v. STATE OF ARKANSAS, (Ark. 2025).

Opinion

Cite as 2025 Ark. 134 SUPREME COURT OF ARKANSAS No. CR-24-374

Opinion Delivered: September 25, 2025 SANTIAGO VASQUEZ, JR. APPELLANT APPEAL FROM THE GREENE COUNTY CIRCUIT COURT [NO. V. 28CR-19-227] STATE OF ARKANSAS HONORABLE RANDY F. APPELLEE PHILHOURS, JUDGE

AFFIRMED; COURT OF APPEALS OPINION VACATED.

BARBARA W. WEBB, Justice

Santiago Vasquez, Jr., was convicted in a Greene County jury trial of five counts of

rape.1 He received an aggregate sentence of 960 months’ imprisonment in the Arkansas

Division of Correction. However, the Arkansas Court of Appeals reversed and remanded

Vasquez’s convictions. Vasquez v. State, 2025 Ark. App. 65, 704 S.W.3d 886. On April 24,

2025, we granted the State’s petition for review.

Upon the grant of a petition for review following a decision by the court of appeals,

we review the case as though the appeal was originally filed with this court. Armer v. State,

326 Ark. 7, 929 S.W.2d 705 (1996). On appeal, Vasquez argues that the circuit court erred

1 This was Vasquez’s third trial on these charges. He was convicted in his first trial, but the court of appeals reversed. Vasquez v. State, 2022 Ark. App. 328, 652 S.W.3d 586 (holding sexual-assault nurse examiner’s (SANE) testimony about frequency of normal findings on sexual-assault exams and children’s delay in disclosing sexual abuse exceeded permissible scope of lay testimony). However, that case was recently overruled by Romick v. State, 2025 Ark. 57, 709 S.W.3d 816. Vasquez’s second trial ended when the jury was unable to reach a unanimous decision. by denying his motion to suppress evidence obtained from his cell phone pursuant to a

search warrant that was so facially deficient as to preclude the “good-faith” exception; and

in permitting the State to question him regarding details from a prior order-of-protection

case in violation of Arkansas Rules of Evidence 404(a)(1), 608, and 613. We vacate the

court of appeals opinion and affirm the circuit court’s order.

I. Denial of the Motion to Suppress

We first consider Vasquez’s argument concerning the denial of his motion to

suppress the evidence seized from the search of his cellular phone. After Vasquez’s arrest, a

search warrant was executed, and an iPhone was discovered inside a black backpack that

was located in his residence. Paragould police submitted to Greene County District Court

Judge Dan Stidham an application for a warrant to search the contents of the phone.

Appended to the application for the warrant was an affidavit executed by

Lieutenant Rhonda Thomas. It stated:

FACT # 1: My name is Lieutenant Rhonda Thomas and I have been employed at the Paragould Police Department since December of 1994. I am currently assigned to the Criminal Division where I work felony cases and supervise the Criminal Division. I have extensive training and experience in working sexually oriented cases involving children.

FACT # 2: On 10/30/2018 a report was received by the Arkansas Department of Human Services in reference to 10-year-old [Minor Victim] who had disclosed sexual acts perpetrated on her by Santiago Vasquez.

FACT # 3: On 11/05/2018 [Minor Victim] was interviewed by a trained forensic interviewer. [Minor Victim] provided graphic details of at least [five] different acts of deviate sexual activity and identified Vasquez as the perpetrator.

FACT # 4: On 02/28/2019 Vasquez was arrested and at the time of his arrest had with him a black backpack. A warrant was obtained and the backpack

2 was searched on 03/01/2019. A cell phone belonging to Vasquez was recovered.

FACT # 5: It is believed that there could be digital evidence on the phone related to the crime of rape being investigated by the Paragould Police Department.

Vasquez filed a motion to suppress the pornographic images seized during the search

of his cell phone. He argued that the affidavit that Thomas executed in support of the

warrant “fail[ed] to set forth particularized facts and circumstances for sufficient probable

cause to search [Vasquez’s] cell phone.” Vasquez asserted that these facts established nothing

more than “the mere fact that he had been arrested for the offense of rape” and “did not

provide a sufficient nexus between the phone and the alleged rape.” Accordingly, Vasquez

urged the circuit court to suppress “any evidence derived from the search of his cell phone.”

Vasquez later filed an amended motion to suppress in which he additionally argued that “the

warrant issued by Judge Stidham is an overbroad, general warrant.” As such, the warrant

authorized police to seize “any digital evidence recovered or related to the offense of rape

being investigated by the Paragould Police Department,” which was “so generalized that

law enforcement searched and seized everything in the records.”

The State responded that probable cause supported the search of Vasquez’s cell

phone, or that, alternatively, the seized evidence should not be suppressed because the

executing officers acted in good faith. According to the State, it was reasonable for Judge

Stidham to infer, from the facts alleged in the affidavit, that there was a nexus between the

alleged rapes and Vasquez’s cell phone. Regarding the good-faith exception, the State

pointed out that “there has been no assertion” that Officer Robert Sexton, who executed

3 the warrant, “acted in bad faith,” or that “Thomas misled or knowingly provided Judge

Stidham with false information.”

The circuit court heard oral argument on the motion to suppress on January 25,

2024. Detective Rhonda Thomas testified that she was a lieutenant over the Criminal

Division in the Paragould Police Department when she applied for the search warrant for

Vasquez’s cell phone. She asserted that she specializes in cases involving child sexual abuse,

and she has assisted several law-enforcement agencies, including the FBI, in their

investigations of those crimes. Regarding the search of Vasquez’s cell phone, Detective

Thomas testified that she “had talked to Judge Stidham at least two times” before preparing

the affidavit for the search warrant. Detective Thomas explained that it was “normal for

[her] to talk with him about cases and tell him, especially when [she] [got] an affidavit for

an arrest, [that] . . . if [Judge Stidham] need[s] more, [she] can give [him] more.”

Nonetheless, she did not specifically remember telling Judge Stidham about the

pornographic images on Vasquez’s cell phone, but she testified that she had “no doubt that

[she] had [that] conversation.” Detective Thomas also testified that she takes special care

when she prepares affidavits of probable cause in cases involving minor victims, and that

she is intentionally “pretty vague in [her] affidavits . . . because [she] know[s] the press is

going to get [them].” She “[tries] not to put a lot of grungy details” in the affidavit but

instead communicates with Judge Stidham about the information he requires for a warrant.

According to Detective Thomas, her work had never been the subject of a successful

suppression motion.

4 At the conclusion of that argument, the circuit court denied the motion to suppress.

Although the circuit court found that the affidavit was insufficient, it nonetheless denied

Vasquez’s motion on the basis of the good-faith exception to the exclusionary rule.

Later, and without any objection from Vasquez, the circuit court allowed the State

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