Page:Jackson v. State, 2013 Ark. 201, 427 S.W.3d 607.pdf/8

 the warning. Under the facts of this case and based on this court's precedent, we cannot say that the circuit court erred in denying the motion to suppress after finding that the purpose of the stop had not been completed at the time K-9 Major was deployed. Accordingly, because the initial purpose of the traffic stop was ongoing, there was no additional reasonable suspicion required to deploy the canine.

We next address Jackson's argument that the circuit court erred in denying his motion to suppress the marijuana because the warrantless search of the vehicle was not reasonable. Specifically, Jackson argues that the factors noted by Corporal Behnke and the alert, without an indication, by K-9 Major were insufficient to establish probable cause to search the vehicle. The State asserts that we should affirm the circuit court's denial of the motion to suppress the marijuana because the positive canine alert by K-9 Major, whose reliability was established by the State, was sufficient to establish probable cause.

The Fourth Amendment to the United States Constitution states as follows:

"The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized."

In general, a search is considered invalid absent a warrant based on probable cause to search. However, the United States Supreme Court first established the "automobile exception" to the warrant requirement in Carroll v. United States, 267 U.S. 132 (1925), recognizing that the mobile nature of automobiles justifies a search, based on probable cause, even when a warrant has not yet been obtained.

Guidelines for warrantless searches of vehicles are set forth in Rule 14.1 of the Arkansas