Ark. Code Ann. » Title 5 Chapter 65
Arkansas Code Annotated

Ark. Code Ann. § 5-65-104 (2026)

Seizure, suspension, and revocation of license — Temporary permits — Ignition interlock restricted license

✓ current as of May 2026
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    1. At the time of arrest for operating or being in actual physical control of a motorboat on the waters of this state or a motor vehicle while intoxicated or while there was an alcohol concentration of eight hundredths (0.08) or more in the person's breath or blood, as provided in § 5-65-103, the arrested person shall immediately surrender his or her driver's license, driver's permit, or other evidence of driving privilege to the arresting law enforcement officer as provided in § 5-65-402.
    2. The Office of Driver Services or its designated official shall suspend or revoke the driving privilege of an arrested person or shall suspend any nonresident driving privilege of an arrested person, as provided in § 5-65-402. The suspension or revocation shall be based on the number of previous offenses as follows:
      1. Suspension for:
          1. Six (6) months for the first offense of operating or being in actual physical control of a motorboat on the waters of this state or a motor vehicle while intoxicated or while there was an alcohol concentration of at least eight hundredths (0.08) by weight of alcohol in the person's blood or breath, § 5-65-103.
          2. If the Office of Driver Services allows the issuance of an ignition interlock restricted license under § 5-65-118, the ignition interlock restricted license shall be available immediately.
          3. The restricted driving permit under § 5-65-120 is not allowed for a suspension under this subdivision (a)(2)(A)(i); and
          1. Suspension for six (6) months for the first offense of operating or being in actual physical control of a motorboat on the waters of this state or a motor vehicle while intoxicated by the ingestion of or by the use of a controlled substance.
          2. The ignition interlock restricted license provision of § 5-65-118 does not apply to a suspension under subdivision (a)(2)(A)(ii)(a) of this section;
        1. Suspension for twenty-four (24) months for a second offense of operating or being in actual physical control of a motorboat on the waters of this state or a motor vehicle while intoxicated or while there was an alcohol concentration of eight hundredths (0.08) or more by weight of alcohol in the person's blood or breath, § 5-65-103, within five (5) years of the first offense.
        2. However, if the office allows the issuance of an ignition interlock restricted license under § 5-65-118, the restricted license is available immediately.
        3. The ignition interlock restricted license provision of § 5-65-118 does not apply to the suspension under subdivisions (a)(2)(B)(i) and (ii) of this section if the person is arrested for an offense of operating or being in actual physical control of a motor vehicle or motorboat while intoxicated by the ingestion of or by the use of a controlled substance;
        1. Suspension for thirty (30) months for the third offense of operating or being in actual physical control of a motorboat on the waters of this state or a motor vehicle while intoxicated or while there was an alcohol concentration of eight hundredths (0.08) or more by weight of alcohol in the person's blood or breath, § 5-65-103, within five (5) years of the first offense.
        2. However, if the office allows the issuance of an ignition interlock restricted license under § 5-65-118, the restricted license is available immediately.
        3. The ignition interlock restricted license provision of § 5-65-118 does not apply to the suspension under subdivisions (a)(2)(C)(i) and (ii) if the person is arrested for an offense of operating or being in actual physical control of a motorboat on the waters of this state or a motor vehicle while intoxicated by the ingestion of or by the use of a controlled substance; and
        1. Revocation for four (4) years, during which no restricted permits may be issued, for the fourth or subsequent offense of operating or being in actual physical control of a motor vehicle or motorboat while intoxicated or while there was an alcohol concentration of eight hundredths (0.08) or more by weight of alcohol in the person's blood or breath, § 5-65-103, within five (5) years of the first offense.
        2. A person whose driver's license is revoked under this subdivision (a)(2)(D) is required to install a functioning ignition interlock device on his or her motor vehicle under § 5-65-118(a)(1)(B) if the person regains his or her driver's license.
    3. If a person is a resident who is convicted of driving without a license or permit to operate a motor vehicle or motorboat and the underlying basis for the suspension, revocation, or restriction of the license or permit was for a violation of § 5-65-103, in addition to any other penalties provided for under law, the court may restrict the offender to an ignition interlock restricted license for a period of one (1) year prior to the reinstatement or reissuance of a license or permit after the person would otherwise be eligible for reinstatement or reissuance of the person's license or permit.
    4. In order to determine the number of previous offenses to consider when suspending or revoking the arrested person's driving privilege, the office shall consider as a previous offense any of the following that occurred within the five (5) years immediately before the current offense:
      1. A conviction for an offense of operating or being in actual physical control of a motorboat on the waters of this state or a motor vehicle while intoxicated or while there was an alcohol concentration of eight hundredths (0.08) or more in the person's breath or blood, including a violation of § 5-10-105(a)(1)(A) or § 5-10-105(a)(1)(B), that occurred:
        1. In Arkansas; or
        2. In another state; or
      2. A suspension or revocation of driving privilege for an arrest for operating or being in actual physical control of a motorboat on the waters of this state or a motor vehicle while intoxicated or while there was an alcohol concentration of eight hundredths (0.08) or more in the person's breath or blood under § 5-65-103 when the person was not subsequently acquitted of the criminal charges.
      1. A person whose driving privilege is suspended or revoked under this section is required to complete an alcohol education program or an alcohol treatment program as approved by the Division of Aging, Adult, and Behavioral Health Services of the Department of Human Services unless the charges are dismissed or the person is acquitted of the charges upon which the suspension or revocation is based.
      2. If during the period of suspension or revocation under subdivision (b)(1)(A) of this section the person commits an additional violation of § 5-65-103, he or she is also required to complete an approved alcohol education program or alcohol treatment program for each additional violation, unless:
        1. The additional charges are dismissed; or
        2. He or she is acquitted of the additional charges.
    2. A person whose driving privilege is suspended or revoked under this section shall furnish proof of:
      1. Attendance at and completion of the alcohol education program or the alcohol treatment program required under subdivision (b)(1) of this section before reinstatement of his or her suspended or revoked driving privilege; or
      2. Dismissal or acquittal of the charge on which the suspension or revocation is based.
    3. Even if a person has filed a de novo petition for review under former subsection (c) of this section, the person is entitled to reinstatement of driving privileges upon complying with this subsection and is not required to postpone reinstatement until the disposition of the de novo review in circuit court has occurred.

History. Acts 1983, No. 549, § 13; 1985, No. 113, § 1; 1985, No. 1064, § 1; A.S.A. 1947, § 75-2511; Acts 1989, No. 368, § 1; 1989, No. 621, § 1; 1993, No. 736, § 1; 1995, No. 802, § 1; 1997, No. 830, § 1; 1997, No. 1325, § 2; 1999, No. 1077, § 9; 1999, No. 1468, § 1; 1999, No. 1508, § 7; 2001, No. 561, §§ 3-5; No. 1501, § 1; 2003, No. 541, § 1; 2003, No. 1036, § 1; 2003, No. 1462, § 1; 2003, No. 1779, § 1; 2005, No. 1234, § 3; 2005, No. 1768, § 1; 2007, No. 712, § 1; 2007, No. 827, § 75; 2007, No. 1196, § 1; 2009, No. 359, §§ 1-3; 2009, No. 650, § 2; 2009, No. 922, § 1; 2009, No. 1293, § 1; 2013, No. 479, §§ 1, 2; 2015, No. 299, § 6; 2017, No. 913, § 18; 2017, No. 1094, § 1.

A.C.R.C. Notes. Acts 2007, No. 827, § 75 provided:

“Acts 1999, No. 1077, § 9, is repealed due to a conflict between that act and Acts 1999, No. 1468, § 1, and Acts 1999, No. 1508, § 7, in amending § 5-65-104, and which conflict under § 1-2-207 is resolved in favor of Acts 1999, Nos. 1468 and 1508.”

Publisher's Notes. Acts 1995, No. 802, § 5(a), is also codified, in part, as §§ 5-65-120(c) and 5-65-205(c).

Amendments. The 2001 amendment by No. 561 rewrote (a)(1), (a)(4), (a)(8), and (a)(9) and made minor stylistic changes.

The 2001 amendment by No. 1501 rewrote this section.

The 2003 amendment by No. 541 added (a)(9)(C) and made related changes.

The 2003 amendment by No. 1036 rewrote this section.

The 2003 amendment by No. 1462 redesignated former (h)(1) as present (b)(1) and deleted the former last three sentences.

The 2003 amendment by No. 1779 substituted “the interlock restrict license shall be available immediately” for “the suspension period for which no restricted license shall be available shall be a minimum of thirty (30) days” in present (a)(2)(A)(iii).

The 2009 amendment by No. 359, in (a)(2), inserted (a)(2)(A)(ii)(b), redesignated the remainder of (a)(2)(A)(ii) accordingly, added (a)(2)(B)(iii) and (a)(2)(C)(iii), and made related changes.

The 2009 amendment by No. 650 inserted “including a violation of § 5-10-105(a)(1)(A) or (B)” in (a)(4)(A).

The 2009 amendment by No. 922, in (a)(2)(B)(ii), substituted “forty-five (45) days, followed by restricted driving privileges to allow driving in any and all of the following situations” for “one (1) year” and inserted (a)(2)(B)(ii)(a) through (a)(2)(B)(ii)(d); in (a)(2)(C)(ii), substituted “forty-five (45) days, followed by restricted driving privileges to allow driving in any and all of the following situations” for “one (1) year” and inserted (a)(2)(C)(ii)(a) through (a)(2)(C)(ii)(d); and made related changes.

The 2009 amendment by No. 1293 rewrote (a)(2)(A).

The 2013 amendment rewrote (a)(2)(B)(ii) and (a)(2)(C)(ii); and, in (a)(3), substituted “court” for “office” and deleted “only” preceding “an ignition”.

The 2015 amendment inserted “motorboat on the waters of this state or a” and “or motorboat” throughout the section; inserted “driver’s” preceding “license” and preceding “permit” in (a)(1); inserted the second and fourth occurrences of “or permit” in (a)(3); deleted (a)(4)(C); in (b)(1)(A), substituted “driving privilege” for “license” and “Division of Behavioral Health Services” for “Office of Alcohol and Drug Abuse Prevention”; rewrote (b)(2); and made stylistic changes.

The 2017 amendment by No. 913 substituted “Division of Aging, Adult, and Behavioral Health Services of the Department of Human Services” for “Division of Behavioral Health Services” in (b)(1)(A).

The 2017 amendment by No. 1094 redesignated former (a)(2)(D) as (a)(2)(D)(i); and added (a)(2)(D)(ii).

Cross References. Effect of administrative revocation on motor vehicle insurance, § 27-22-106.

Administrative driver's license suspension, § 5-65-401 et seq.

Research References

U. Ark. Little Rock L.J.

Legislative Survey, Criminal Law, 8 U. Ark. Little Rock L.J. 559.

Survey of Legislation, 2001 Arkansas General Assembly, Criminal Law, 24 U. Ark. Little Rock L. Rev. 429.

Survey of Legislation, 2003 Arkansas General Assembly, Criminal Law, Driving While Intoxicated, 26 U. Ark. Little Rock L. Rev. 367.

Case Notes

Constitutionality.

Sections 5-65-107, 5-65-109, and this section do not violate the doctrines of prosecutorial discretion and separation of powers. Johnston v. City of Fort Smith, 15 Ark. App. 102, 690 S.W.2d 358 (1985) (decision prior to 1989 amendment).

This section does not violate the constitutional prohibition on double jeopardy; this section does not impose multiple punishments for the same offense. Pyron v. State, 330 Ark. 88, 953 S.W.2d 874 (1997).

Administrative suspension of a license for 180 days did not rise to the level of punishment because the suspension was that of a privilege, not a right, to operate a motor vehicle; and the Double Jeopardy Clause was not violated by a subsequent conviction on criminal charges. Pyron v. State, 330 Ark. 88, 953 S.W.2d 874 (1997).

The temporary revocation of the privilege of driving for refusal to submit to a chemical analysis is rationally related to the purpose of this section, which is to protect the public from intoxicated drivers and to reduce alcohol-related accidents. Pyron v. State, 330 Ark. 88, 953 S.W.2d 874 (1997).

In General.

This section does not take the power of license suspension from the jury; rather, it only directs the court to perform certain acts in executing the sentence. Tharp v. State, 294 Ark. 615, 745 S.W.2d 612 (1988).

Construction.

Although defendant was charged with DWI second offense but convicted instead of DWI first offense, the defendant was not acquitted of the “charge” of DWI second offense; once the municipal court convicted defendant of DWI first offense, he simply had two separate convictions of violating § 5-65-103, since DWI first offense is just as much a violation of § 5-65-103 as is DWI second offense. Leathers v. Cotton, 332 Ark. 49, 961 S.W.2d 32 (1998).

Burden of Proof.

The standard for administrative license suspension is based on the civil standard of proof by a preponderance of the evidence, a lower standard than that required for a criminal conviction. Pyron v. State, 330 Ark. 88, 953 S.W.2d 874 (1997).

Jurisdiction.

The court had authority to suspend the driver's license of defendant convicted of driving while intoxicated and speeding, notwithstanding the contention that only the Department of Finance and Administration can suspend a license for driving while intoxicated, since the court still had authority, pursuant to § 27-50-306, to suspend the defendant's driver's license for moving traffic violations. Cook v. State, 333 Ark. 22, 968 S.W.2d 589 (1998).

Purpose.

The purpose for the sanctions is to prevent drunk driving, and it is clear that the legislative intent was to provide remedial civil sanctions. Pyron v. State, 330 Ark. 88, 953 S.W.2d 874 (1997).

The legislature intended to establish a remedial civil sanction for the purpose of protecting the public from intoxicated drivers and to reduce alcohol-related accidents while softening the sanctions in order to allow the person to continue to operate a vehicle for appropriate purposes. Pyron v. State, 330 Ark. 88, 953 S.W.2d 874 (1997).

Prior Convictions.

Trial court properly granted defendant's pretrial motion to suppress evidence of his three prior driving while intoxicated convictions because in those earlier proceedings he was not represented by counsel. State v. Brown, 283 Ark. 304, 675 S.W.2d 822 (1984).

The legislative intent of the Omnibus DWI Act of 1983, as stated in former § 5-65-101(b), was to enhance penalties by using convictions under the older driving while under the influence act; thus, previous convictions for driving while under the influence under the prior law of intoxicants may be used as prior offenses for enhancement purposes. Lovell v. State, 283 Ark. 425, 678 S.W.2d 318 (1984).

Where certificates of prior convictions did not reflect that the defendants were represented by counsel at prior trials, admission of the documents held to be error. Lovell v. State, 283 Ark. 425, 678 S.W.2d 318 (1984).

A prior conviction cannot be used collaterally to impose enhanced punishment, unless the misdemeanant was represented by counsel or validly waived counsel. Lovell v. State, 283 Ark. 425, 678 S.W.2d 318 (1984); Hegler v. State, 286 Ark. 215, 691 S.W.2d 129 (1985).

If the record of one of three prior driving while intoxicated convictions is silent as to representation or waiver of counsel, the conviction cannot be used as evidence that the offense charged is a second or subsequent DWI offense. Peters v. State, 286 Ark. 421, 692 S.W.2d 243 (1985).

Evidence that the defendant was assisted by counsel at the trial of his prior DWI conviction was held insufficient, and therefore, because there was not sufficient evidence of representation, the defendant's third conviction could not be used as evidence that the present conviction was his fourth. Peters v. State, 286 Ark. 421, 692 S.W.2d 243 (1985).

Two separate convictions of DWI first offense, both violations of § 5-65-103, should be counted as two “previous offenses.” Leathers v. Cotton, 332 Ark. 49, 961 S.W.2d 32 (1998).

Sentence.

The sentencing provisions of the Omnibus DWI Act of 1983 are mandatory; where imprisonment is required, such a sentence cannot be reduced or suspended by the judge. Lovell v. State, 283 Ark. 434, 681 S.W.2d 395 (1984).

The legislature enacted § 5-65-120 to allow those with no alternate means of commuting to and from work to apply for a restricted driving permit; this section rebuts any argument concerning the punitive effect of the sanction upon a person whose license has been suspended, as a result of which his ability to maintain his means of livelihood is impaired. Pyron v. State, 330 Ark. 88, 953 S.W.2d 874 (1997).

Second-offense sanctions could be imposed on defendant with two convictions for DWI first offense. Leathers v. Cotton, 332 Ark. 49, 961 S.W.2d 32 (1998).

Temporary Permit.

This section clearly provides for a temporary permit to be issued upon arrest, which remains valid until the trial, but, after a guilty plea or conviction of a first offender, the temporary permit does not continue indefinitely until the first offender receives notice of the right to apply for a restricted license. Liggett v. State, 309 Ark. 608, 832 S.W.2d 813 (1992).

Cited: Rawlings v. State, 284 Ark. 446, 683 S.W.2d 223 (1985); Urich v. State, 293 Ark. 246, 737 S.W.2d 155 (1987); Phillips v. State, 304 Ark. 656, 803 S.W.2d 926 (1991); Gorman v. State, 366 Ark. 82, 233 S.W.3d 622 (2006).

Notes of Decisions
Cited in 13 cases (1 in the last 5 years), 1988–2021 · leading case: Leathers v. Cotton, 961 S.W.2d 32 (Ark. 1998).
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Leathers v. Cotton, 961 S.W.2d 32 (Ark. 1998). · cites it 28× “Pursuant to Ark. Code Ann. § 5-65-104 (Repl. 1997), Cotton’s license was temporarily suspended by the Office of Driver Services of the Revenue Division of the Department of Finance & Administration, and Cotton subsequently exercised his right to an administrative hearing.”
Weiss v. Johnson, 961 S.W.2d 28 (Ark. 1998). · cites it 46× “That the de novo review conducted in circuit court pursuant to Ark.Code Ann. § 5-65-104 is a "special hearing.”
Wright v. City of Little Rock, 233 S.W.3d 644 (Ark. 2006). · cites it 8× “" Ark.Code Ann. § 5-65-104(c) (Repl.1997). DF & A failed to appear at the hearing, and the trial court entered a judgment in favor of the appellee.”
Norris v. State, 993 S.W.2d 918 (Ark. 1999). · cites it 4× “See Ark. Code Ann. §§ 5-65-103 ; 5-65-lll(a) (Repl.”
Pyron v. State, 953 S.W.2d 874 (Ark. 1997). · cites it 7× “With regard to the first prong of this test, we note that Ark. Code Ann. § 5-65-104 (Supp. 1995) states: The administrative suspension or revocation of a driver’s license as provided for by this section shall be supplementary to and in addition to the suspensions or revocations…”
Mercury Mktg. Tech. of Delaware, Inc. v. State Ex Rel. Beebe, 189 S.W.3d 414 (Ark. 2004). · cites it 8× “Pursuant to Ark.Code Ann. § 5-65-104 (Repl.1997), the appellee filed a "de novo petition for review" of the agency determination in circuit court.”
Tharp v. State, 745 S.W.2d 612 (Ark. 1988). · cites it 2× “1985) [now codified with minor stylistic changes at Ark. Code Ann. § 5-65-104 (1987)], which provides, “[T]he court shall transmit the operator’s license to the Office of Driver Services and shall instruct the Office of Driver Services to suspend or revoke such person’s motor…”
Cook v. State, 968 S.W.2d 589 (Ark. 1998). · cites it 8× “At the subsequent sentencing hearing, the circuit court asked if Cook’s driver’s license had been suspended by the Department of Finance and Administration (DF&A) pursuant to Ark. Code Ann. § 5-65-104 (Repl. 1997). Cook’s counsel told the judge that a hearing had been conducted…”
Hatley v. State, 5 S.W.3d 86 (Ark. Ct. App. 1999). “(b) The Office of Driver Services shall then proceed to suspend or revoke the driving privilege of the arrested person, or any nonresident’s driving privilege, on the basis of the number of previous offenses in accordance with the provisions of § 5-65-104. The following…”
Phillips v. State, 803 S.W.2d 926 (Ark. 1991). · cites it 2× “See Omnibus DWI Act, [ Ark. Code Ann. §§ 5-65-104 (a)(4), 111(a), 112, 113(a), and 115(a) (1987 & Supp.”
Arkansas Dep't of Fin. & Admin., Larry W. Walther, Dir.; Marla McHughes, Darryl Hall, & Melony Turner, in Their Off. Capacities v. Mark Lewis, 2021 Ark. 213 (Ark. 2021). · cites it 2× “See generally Ark. Code Ann. § 5-65-104 (Supp. 2021). One requirement for reinstatement of a driver’s license after a DWI conviction is the attendance of a Victim Impact Panel (VIP).”
Gorman v. State, 233 S.W.3d 622 (Ark. 2006). · cites it 2× “Appellant’s license was suspended for driving while intoxicated (DWI), pursuant to Ark. Code Ann. § 5-65-104 (Supp. 2003). On appeal, appellant challenges the sufficiency of the evidence to support his conviction and the circuit court’s denial of his motion to suppress a…”
Show all 13 citing cases →
— Ark. Code Ann. § 5-65-104(a) — 1 case
Pyron v. State, 953 S.W.2d 874 (Ark. 1997). “With regard to the first prong of this test, we note that Ark. Code Ann. § 5-65-104 (Supp. 1995) states: The administrative suspension or revocation of a driver’s license as provided for by this section shall be supplementary to and in addition to the suspensions or revocations…”
— Ark. Code Ann. § 5-65-104(a)(2) — 1 case
Weiss v. Johnson, 961 S.W.2d 28 (Ark. 1998). “That the de novo review conducted in circuit court pursuant to Ark.Code Ann. § 5-65-104 is a "special hearing.”
— Ark. Code Ann. § 5-65-104(a)(3) — 1 case
Weiss v. Johnson, 961 S.W.2d 28 (Ark. 1998). “That the de novo review conducted in circuit court pursuant to Ark.Code Ann. § 5-65-104 is a "special hearing.”
— Ark. Code Ann. § 5-65-104(a)(4)(A)(I) — 1 case
Norris v. State, 993 S.W.2d 918 (Ark. 1999). “See Ark. Code Ann. §§ 5-65-103 ; 5-65-lll(a) (Repl.”
— Ark. Code Ann. § 5-65-104(a)(7) — 1 case
Weiss v. Johnson, 961 S.W.2d 28 (Ark. 1998). “That the de novo review conducted in circuit court pursuant to Ark.Code Ann. § 5-65-104 is a "special hearing.”
— Ark. Code Ann. § 5-65-104(a)(8)(A) — 1 case
Weiss v. Johnson, 961 S.W.2d 28 (Ark. 1998). “That the de novo review conducted in circuit court pursuant to Ark.Code Ann. § 5-65-104 is a "special hearing.”
— Ark. Code Ann. § 5-65-104(a)(9)(A) — 1 case
Leathers v. Cotton, 961 S.W.2d 32 (Ark. 1998). “Pursuant to Ark. Code Ann. § 5-65-104 (Repl. 1997), Cotton’s license was temporarily suspended by the Office of Driver Services of the Revenue Division of the Department of Finance & Administration, and Cotton subsequently exercised his right to an administrative hearing.”
— Ark. Code Ann. § 5-65-104(a)(l) — 1 case
Liggett v. State, 832 S.W.2d 813 (Ark. 1992).
— Ark. Code Ann. § 5-65-104(b)(1) — 1 case
Liggett v. State, 832 S.W.2d 813 (Ark. 1992).
— Ark. Code Ann. § 5-65-104(c) — 4 cases
Weiss v. Johnson, 961 S.W.2d 28 (Ark. 1998). “That the de novo review conducted in circuit court pursuant to Ark.Code Ann. § 5-65-104 is a "special hearing.”
Leathers v. Cotton, 961 S.W.2d 32 (Ark. 1998). “Pursuant to Ark. Code Ann. § 5-65-104 (Repl. 1997), Cotton’s license was temporarily suspended by the Office of Driver Services of the Revenue Division of the Department of Finance & Administration, and Cotton subsequently exercised his right to an administrative hearing.”
Wright v. City of Little Rock, 233 S.W.3d 644 (Ark. 2006). “" Ark.Code Ann. § 5-65-104(c) (Repl.1997). DF & A failed to appear at the hearing, and the trial court entered a judgment in favor of the appellee.”
Mercury Mktg. Tech. of Delaware, Inc. v. State Ex Rel. Beebe, 189 S.W.3d 414 (Ark. 2004). “Pursuant to Ark.Code Ann. § 5-65-104 (Repl.1997), the appellee filed a "de novo petition for review" of the agency determination in circuit court.”
— Ark. Code Ann. § 5-65-104(d)(2)(B) — 1 case
Leathers v. Cotton, 961 S.W.2d 32 (Ark. 1998). “Pursuant to Ark. Code Ann. § 5-65-104 (Repl. 1997), Cotton’s license was temporarily suspended by the Office of Driver Services of the Revenue Division of the Department of Finance & Administration, and Cotton subsequently exercised his right to an administrative hearing.”
— Ark. Code Ann. § 5-65-104(f) — 1 case
Pyron v. State, 953 S.W.2d 874 (Ark. 1997). “With regard to the first prong of this test, we note that Ark. Code Ann. § 5-65-104 (Supp. 1995) states: The administrative suspension or revocation of a driver’s license as provided for by this section shall be supplementary to and in addition to the suspensions or revocations…”
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