Thus, for our purposes, it has been established that law-enforcement officers were attempting to execute an arrest warrant on Alonzo at what they reasonably believed to be his home, and the third-party analysis of Steagald is not applicable. Under Payton, officers executing an arrest warrant at a residence must have (1) a reasonable belief that the suspect resides at the place to be entered and (2) reason to believe the suspect is present. United States v. Risse, 83 F.3d 212 (8th Cir. 1996); Benavidez v. State, 352 Ark. 374, 375, 101 S.W.3d 242, 243 (2003). "[T]he officers' assessment need not in fact be correct; rather, they need only 'reasonably believe' that the suspect resides at the dwelling to be searched and is currently present at the dwelling."

12. SEARCH SEIZURE — ENTRY INTO HOME BASED ON MISDEMEANOR ARREST WARRANT — OFFICERS MAY ENTER DWELLING IF THEY HAVE VALID ARREST WARRANT REASON TO BELIEVE THAT SUSPECT LIVES IN DWELLING AND IS WITHIN IT. — Although our supreme court has not explicitly held that a misdemeanor arrest warrant is sufficient for an officer's entrance into a home, the Eighth Circuit Court of Appeals, in United States v. Clayton, 210 F.3d 841, 843 (8th Cir. 2000), has held that this principle is applicable to both felony and misdemeanor arrest warrants; furthermore, Benevidez v. State, 352 Ark. 374, 101 S.W.3d 242 (2003), explicitly allows officers to enter a dwelling if they have a valid arrest warrant and reason to believe that the suspect lives in the dwelling and is within it. 13. SEARCH SEIZURE — ARREST WARRANTS WERE VALID AND OFFICERS HAD RECEIVED INFORMATION THAT APPELLANT WAS INSIDE RESIDENCE — OFFICERS' APPROACH TO FRONT DOOR OF TRAILER WAS PROPER. — Appellant's argument that the officers improperly crossed the threshold of what the officers described as a carport to serve the valid arrest warrants because that was part of his residence and he had an expectation of privacy in that area was unsuccessful where the testimony at trial was that the door could not be locked, that there was no longer screening around the area, and that you could walk between the wooden posts; furthermore, two witnesses testified that the trailer door, not the door on the outside of what the officers described as the carport, was the door that was approached and knocked upon when desiring entry into the trailer;

Pursuant to Payton, officers executing an arrest warrant at a residence must have (1) a reasonable belief that the suspect resides at the place to be entered and (2) reason to believe that the suspect is present at the time the warrant is executed. United States v. Risse, 83 F.3d 212, 216 (8th Cir.1996); see alsoBenavidez v. State, 352 Ark. 374, 379–80, 101 S.W.3d 242, 246–47 (2003) (applying Payton analysis); Gutierrez v. State, 2012 Ark. App. 628, at 6–7, 2012 WL 5439949 (same). Evans does not argue that the outstanding warrant for his arrest was invalid.

Clearly the touchstone principle in any Fourth Amendment analysis is reasonableness, and in making a reasonableness determination it is necessary for a court to consider the totality of the circumstances. See Benavidez v. State, 352 Ark. 374, 101 S.W.3d 242 (2003); see also Ohio v. Robinette, 519 U.S. 33, 117 S.Ct. 417, 136 L.Ed.2d 347 (1996) (stating that reasonableness is measured in objective terms by examining the totality of the circumstances). No such analysis occurred in this case.

The police officers were aware of this, they had current and reliable information that appellant and her boyfriend were then present in Room 142, and the circumstances supported a reasonable belief that the motel room was serving as their residence. Our supreme court's holding in Benevidez v. State, 352 Ark. 374, 101 S.W.3d 242 (2003), explicitly allows officers to enter a dwelling if they have a valid arrest warrant and reason to believe that the suspect lives in the dwelling and is within it. In light of that holding and the circumstances of this case, we hold that the trial court did not err in declining to suppress items found in plain view in the motel room while appellant's boyfriend was being apprehended.

Under our standard of review, we are required to analyze this question employing an objective standard in reviewing the totality of the circumstances. Benavidez v. State, 352 Ark. 374, 101 S.W.3d 242 (2003). This review necessarily means doing more than looking at the arresting officer's testimony that the appellant's consent was voluntary. However, after careful consideration, and multiple readings of the trial court's rulings with regard to the search, I have concluded that the issue of the validity of Mr. Jackson's consent is not preserved for appellate review.

See also United States v. Kaylor, 877 F.2d 658, 663 (8th Cir. 1989) ("Kaylor cannot claim any greater Fourth Amendment protection in the . . . home [of a third party] than he possessed in his own home"; thus, "possession of a warrant for Kaylor's arrest and the officers' reasonable belief of his presence in the . . . home [of a third party] justified the entry without a search warrant"); United States v. Underwood, 717 F.2d 482, 484 (9th Cir. 1983) ("A person has no greater right of privacy in another's home than in his own. If an arrest warrant and reason to believe the person named in the warrant is present are sufficient to protect that person's fourth amendment privacy rights in his own home, they necessarily suffice to protect his privacy rights in the home of another."); Benavidez v. State, 352 Ark. 374, 379, 101 S.W.3d 242, 246 (2003) (holding that law-enforcement officers did not need a search warrant to enter third party's apartment where the defendant was living to execute an arrest warrant for the defendant); State v. Shaw, 113 S.W.3d 335, 338 (Tenn.Crim.App. 2002) (assuming defendant had expectation of privacy in home of third party in which he was arrested, he "was only entitled to the protection given him under Payton that requires law enforcement to obtain a warrant for his arrest and have reason to believe he is inside the premises"); State v. Williams, 142 Wash.2d 17, 24, 11 P.3d 714, 718 (2000) ("We find no reason to confer additional privacy protections to suspects who are arrested in other person's homes."); State v. Tolbert, 116 Ohio App.3d 86, 686 N.E.2d 1375 (1996) (holding that search warrant was not necessary for police to enter third party's home to arrest defendant pursuant to an arrest warrant because defendant was not entitled to greater Fourth Amendment protections while in a third party's ho

We do not reverse the trial court's decision unless it was clearly erroneous. Benevidez v. State, 352 Ark. 374, 101 S.W.3d 242 (2003). Here, we affirm the trial court's denial of appellant's motion to suppress.

See also United States v. Kaylor, 877 F.2d 658, 663 (8th Cir. 1989) ("Kaylor cannot claim any greater Fourth Amendment protection in the . . . home [of a third party] than he possessed in his own home"; thus, "possession of a warrant for Kaylor's arrest and the officers' reasonable belief of his presence in the . . . home [of a third party] justified the entry without a search warrant"); United States v. Underwood, 717 F.2d 482, 484 (9th Cir. 1983) ("A person has no greater right of privacy in another's home than in his own. If an arrest warrant and reason to believe the person named in the warrant is present are sufficient to protect that person's fourth amendment privacy rights in his own home, they necessarily suffice to protect his privacy rights in the home of another."); Benavidez v. State, 352 Ark. 374, 379, 101 S.W.3d 242, 246 (2003) (holding that law-enforcement officers did not need a search warrant to enter third-party's apartment where the defendant was living to execute an arrest warrant for the defendant); State v. Shaw, 113 S.W.3d 335, 338 (Tenn.Crim.App. 2002) (assuming defendant had expectation of privacy in home of third party in which he was arrested, he "was only entitled to the protection given him under Payton that requires law enforcement to obtain a warrant for his arrest and have reason to believe he is inside the premises"); State v. Williams, 142 Wash.2d 17, 24, 11 P.3d 714, 718 (2000) ("We find no reason to confer additional privacy protections to suspects who are arrested in other person's homes."); State v. Tolbert, 116 Ohio App. 3d 86, 686 N.E.2d 1375 (1996) (holding that search warrant was not necessary for police to enter third party's home to arrest defendant pursuant to an arrest warrant because defendant was not entitled to greater Fourth Amendment protections while in a third party's