Justia Arkansas Supreme Court Opinion Summaries

Bryant Smith was convicted in the Jefferson County Circuit Court of two counts of capital murder, one count of attempted capital murder, five counts of first-degree unlawful discharge of a firearm from a vehicle, one count of second-degree unlawful discharge of a firearm from a vehicle, six counts of terroristic act, and one count of unauthorized use of property to facilitate a crime. These charges stemmed from the deaths of a seventeen-year-old and a twenty-year-old, and the injury of another individual on September 3, 2020. Smith received a life sentence without the possibility of parole.The Jefferson County Circuit Court admitted evidence that Smith possessed a firearm when he was arrested, despite Smith's objections. The court also admonished a witness, Asia Holman, to tell the truth after she gave inconsistent testimony. Smith's motion to strike Holman's testimony was denied. The court ruled that Smith's prior convictions mandated life sentences for the noncapital Class Y felonies. Additionally, the court gave a nonmodel jury instruction that evidence of Smith's flight could be considered as evidence of guilt.The Arkansas Supreme Court reviewed the case and affirmed the lower court's decisions. The court held that substantial evidence supported Smith's convictions, including his own confession and corroborating evidence. The court found no abuse of discretion in admitting evidence of Smith's firearm possession, as it was relevant to the context of his flight and confession. The court also ruled that the circuit court's admonition to Holman was not an improper comment on the evidence and that the court did not err in refusing to strike her testimony. The court upheld the mandatory life sentences based on Smith's criminal history and found the nonmodel jury instruction on flight to be appropriate. Finally, the court determined that there was no error in the sentencing order that required correction. View "SMITH v. STATE OF ARKANSAS" on Justia Law

Dean Meacham was convicted of three counts of raping his minor daughter, referred to as MV, and was sentenced to three concurrent life sentences. MV disclosed the abuse at age thirteen, leading to Meacham's arrest and subsequent trial. Forensic evidence, including Meacham's semen on MV's bedsheets, supported the charges. Meacham appealed his convictions on four grounds, arguing that the circuit court erred in allowing certain testimonies and denying his motion for a mistrial.The Washington County Circuit Court denied Meacham's motion in limine to exclude evidence of him videoing MV naked in the shower, finding it admissible under the pedophile exception to Rule 404(b). At trial, the court overruled objections to testimonies from Debbee Deckard, a forensic interviewer, and Jessica Faamafi, MV's mother, regarding MV's disclosure of abuse and the video evidence. The court also denied Meacham's motion for a mistrial related to MV's reference to gender-identity issues during her testimony.The Supreme Court of Arkansas reviewed the case and affirmed the circuit court's decisions. The court held that Deckard's testimony was admissible as nonhearsay to show her course of conduct during the interview. Faamafi's testimony about the video was admissible under the pedophile exception to Rule 404(b), since it demonstrated Meacham's deviate sexual interest in MV. The court found that the probative value of this evidence outweighed any potential prejudice.Regarding the motion for a mistrial, the court determined that the circuit court did not abuse its discretion in denying the motion or in refusing to admonish the jury. The court concluded that MV's brief and incomplete statement about her gender identity did not prejudice Meacham. Consequently, the Supreme Court of Arkansas affirmed Meacham's convictions and sentences. View "Meacham v. State" on Justia Law

In this case, the appellant, Justin Mays, was convicted by a Pulaski County Circuit Court jury of capital murder, two counts of terroristic act, and one count of first-degree battery. The incident occurred on August 21, 2021, when Mays was involved in a shooting on Interstate 40. Mays was identified as the shooter who fired from a black Dodge Charger at a red Ford Mustang, resulting in the death of Kindelyn Roberts and injuries to others. Mays was sentenced to life imprisonment without parole for the capital murder conviction and additional concurrent sentences for the other charges, including firearm enhancements.The Pulaski County Circuit Court jury found Mays guilty based on testimonies and evidence presented during the trial. Witnesses, including Arkansas State Police officers and other involved parties, provided accounts of the events leading to the shooting. The jury found substantial evidence that Mays was the shooter or an accomplice in the crimes. Mays's appeal challenged the sufficiency of the evidence for each conviction.The Supreme Court of Arkansas reviewed the case, focusing on whether there was substantial evidence to support the jury's verdicts. The court held that the testimonies and physical evidence presented at trial were sufficient to affirm Mays's convictions. The court found that the evidence, including ballistic analysis and witness statements, supported the conclusion that Mays fired the shots that resulted in the death of Roberts and injuries to others. The court affirmed the convictions and sentences, concluding that the circuit court did not err in denying Mays's motions for directed verdict. View "Mays v. State" on Justia Law

On June 28, 2023, Justin Mays was convicted by a Pulaski County Circuit Court jury of capital murder, two counts of terroristic act, and one count of first-degree battery. Mays was sentenced to life imprisonment without parole for the capital murder conviction and ten years for each of the remaining convictions, to be served concurrently with his life sentence. He also received four 10-year sentence enhancements for the use of a firearm during the commission of the crimes, to run concurrently with each other, resulting in an aggregate sentence of life imprisonment plus ten years. Mays appealed, challenging the sufficiency of the evidence for each conviction.The Pulaski County Circuit Court found Mays guilty based on evidence presented at trial, including testimony from Arkansas State Police officers and other witnesses. The evidence showed that Mays was involved in a shooting on Interstate 40, where he fired multiple shots from a black Dodge Charger at a red Ford Mustang, resulting in the death of Kindelyn Roberts and injuries to others. Mays was identified as the shooter by a co-defendant, and ballistic evidence supported this identification.The Arkansas Supreme Court reviewed the case and affirmed the convictions. The court held that there was substantial evidence to support the jury's findings. The court noted that the testimony of the co-defendant, corroborated by physical evidence and other witness statements, was sufficient to establish Mays's guilt. The court also found that the evidence was consistent with Mays's guilt and inconsistent with any other reasonable conclusion. The court concluded that the circuit court did not err in denying Mays's motions for directed verdict and upheld the convictions and sentences. View "MAYS v. STATE OF ARKANSAS" on Justia Law

Willie McDaniels was convicted by a jury of two counts of rape and sentenced to concurrent terms of 480 months’ imprisonment for each count. The Arkansas Court of Appeals affirmed his conviction on direct appeal. McDaniels subsequently sought postconviction relief under Arkansas Rule of Criminal Procedure 37.1, which was denied by the circuit court, and the denial was affirmed by the Arkansas Supreme Court.McDaniels later filed a pro se petition to correct an illegal sentence under Arkansas Code Annotated section 16-90-111, arguing that his sentences were illegal because they departed from the sentencing guidelines. The Pulaski County Circuit Court, Third Division, found that his sentences were not illegal as they were within the statutory range for a Class Y felony, which carries a sentencing range of ten to forty years or life. Consequently, the circuit court denied his petition.On appeal to the Arkansas Supreme Court, McDaniels abandoned his original argument regarding the sentencing guidelines and instead claimed that his Sixth Amendment right to a fair and impartial jury was violated due to ineffective assistance of trial counsel. He argued that his counsel was ineffective for remaining silent when the trial court ordered the jury to continue deliberations after initially returning a hung verdict on one count, being inattentive during the trial, and failing to ensure documentation supporting the sentencing departure was attached to the judgment and commitment order. However, these arguments were not raised in the lower court.The Arkansas Supreme Court affirmed the circuit court’s denial of McDaniels’s petition, noting that arguments not raised below cannot be addressed on appeal, and issues raised below but not argued on appeal are considered abandoned. View "MCDANIELS v. STATE OF ARKANSAS" on Justia Law

Billy Michael Nelson was convicted of raping a minor under fourteen years of age and, due to a prior rape conviction, received a mandatory life sentence. The case arose when a ten-year-old girl reported to her friend and subsequently to her teacher that she had "hickeys" on her chest, which led to a hospital examination and involvement of the Union County Sheriff’s Office. The victim identified Nelson, her neighbor, as the perpetrator, stating that he had sex with her while she was at his house doing homework.The Union County Circuit Court denied Nelson's motion to suppress his custodial statement, which he argued was coerced and involuntary. Nelson was Mirandized and signed a waiver before being interviewed by Sergeant Jim Sanders, who made statements suggesting he had substantial evidence, including DNA, and sought Nelson's side of the story. Nelson eventually admitted to inappropriate conduct with the victim after initially denying it.The Arkansas Supreme Court reviewed the case and upheld the lower court's decision. The court found that the officer's statements during the interrogation, although potentially misleading, were not calculated to procure an untrue statement and were intended to elicit the truth. The court also determined that the officer's comments did not constitute unambiguous promises of leniency. Considering Nelson's age, intelligence, prior criminal experience, and the context of the interrogation, the court concluded that his statement was voluntary and not coerced. The conviction and life sentence were affirmed. View "Nelson v. State" on Justia Law

Eathan Cypert was convicted of first-degree murder and sentenced to life imprisonment plus 15 years for killing his wife, Kristina. The incident occurred around 2 a.m. on July 2, 2022, when Cypert shot Kristina in the back with an AR-15 following an argument. Evidence included a trail of blood, six bullet casings, and testimony from a medical examiner and on-scene investigator. Cypert was apprehended later that night, and his clothing tested positive for gunshot residue. He was charged with first-degree murder and a firearm enhancement. During the trial, the court allowed testimony about Kristina's prior bruising and Cypert's violent behavior. The jury found Cypert guilty, and he was sentenced accordingly.The Crawford County Circuit Court entered the judgment and sentence on January 29, 2024. After the verdict, a juror informed Cypert’s counsel of potential juror misconduct during deliberations. Cypert filed a motion for a new trial based on this information, which the circuit court denied on February 27, 2024. Cypert did not amend his notice of appeal to include this denial, nor did he request the voir dire or post-trial hearing transcript in the appellate record.The Supreme Court of Arkansas reviewed the case. They concluded that they lacked jurisdiction to review the denial of Cypert’s post-trial motion for a new trial based on juror misconduct because he failed to amend his notice of appeal to cover that order. Additionally, the court held that Cypert was not entitled to a second-degree murder instruction because the record did not support that instruction. The court affirmed the conviction and sentence, finding no error in the lower court's rulings. View "Cypert v. State" on Justia Law

James Woods was convicted of one count of engaging a child in sexually explicit conduct for use in visual or print medium and one count of pandering or possessing visual or print medium of a child engaging in sexually explicit conduct. Over three months, Woods raped and sexually assaulted a minor victim, filming the acts. The State charged him with multiple counts, including rape and sexual assault. A Lawrence County jury convicted him on eight counts, sentencing him to life imprisonment plus 149 years. Woods appealed, challenging the sufficiency of evidence for one pandering and one engaging conviction, both related to a two-second video of the minor victim’s bloody vagina.The Lawrence County Circuit Court granted Woods’s directed verdict for one pandering and one engaging charge but denied it for the remaining counts. The jury convicted Woods on the remaining counts. On appeal, Woods argued that there was insufficient evidence to support the two challenged convictions.The Supreme Court of Arkansas reviewed the case, noting that a motion for a directed verdict challenges the sufficiency of the evidence. The court views evidence in the light most favorable to the State and affirms if substantial evidence supports the conviction. Substantial evidence can be direct or circumstantial. The court found that the evidence, including the minor victim’s and her mother’s testimonies, Woods’s comments, and the videos found on Woods’s phone, was sufficient to support the convictions. The court concluded that the jury could reasonably determine that Woods filmed the video and that it depicted the minor victim.The Supreme Court of Arkansas affirmed Woods’s convictions, finding substantial evidence to support them. The court also reviewed the record for prejudicial errors and found none. View "Woods v. State" on Justia Law

In December 2021, Deanna Teague and her daughter were moving into a new apartment in Lamar, Arkansas. Deanna was last seen on December 3, 2021, with Chris Oliger, who was helping her move. When Deanna failed to pick up her daughter from a sleepover, her daughter went to check on her and found the apartment trashed, with blood and a missing car. Deanna's body was discovered inside the apartment. The medical examiner confirmed that Deanna had been stabbed multiple times, with a fatal wound to the throat. DNA evidence linked Oliger to the crime scene, and social media messages revealed his plan to rob Deanna.The Johnson County Circuit Court convicted Oliger of capital murder, aggravated robbery, and theft of property. The jury found him guilty under both felony murder and premeditated murder theories. Oliger received life sentences for capital murder and aggravated robbery, and 144 months for theft of property. Oliger appealed, arguing insufficient evidence to support the verdicts.The Supreme Court of Arkansas reviewed the case. The court held that substantial evidence supported the convictions. The court noted that Oliger's social media messages before and after the murder indicated his intent to rob Deanna. Additionally, Oliger admitted to stabbing Deanna, and evidence showed he used her financial assets after her death. The court affirmed the capital murder conviction based on the felony murder theory, as the murder and robbery were part of the same transaction. The court also affirmed the aggravated robbery conviction, finding substantial evidence that Oliger intended to and did commit robbery, causing Deanna's death. The court found no prejudicial error in the record and affirmed the convictions. View "Oliger v. State" on Justia Law

Hunter de la Garza, a former employee of the Northwest Arkansas Children’s Shelter, was convicted of raping a ten-year-old female resident of the Shelter. The incident occurred during an outing to a mall, where de la Garza followed the victim into a restroom, forcibly undressed her, and raped her. The victim disclosed the rape to her brother and a friend, and later to a professional interviewer. The Shelter’s staff observed behavioral changes in the victim consistent with sexual abuse. De la Garza was interviewed by police and provided inconsistent accounts of the events.The Benton County Circuit Court denied de la Garza’s motion for a directed verdict, finding sufficient evidence to support the conviction. The court also allowed testimony from another young female resident of the Shelter, who described similar abuse by de la Garza, under the “pedophile exception” to Rule 404(b) of the Arkansas Rules of Evidence. The jury found de la Garza guilty and sentenced him to life in prison. De la Garza’s motion for a new trial was denied.The Arkansas Supreme Court reviewed the case and affirmed the conviction. The court held that the victim’s testimony, along with corroborating evidence, constituted substantial evidence to support the conviction. The court also found no abuse of discretion in admitting the testimony of the other young resident under the pedophile exception. Additionally, the court determined that de la Garza’s arguments regarding prosecutorial comments were not preserved for appeal, as he failed to contemporaneously object or request further relief during the trial. The court conducted a Rule 4-3(a) review and found no prejudicial error. View "HUNTER DE LA GARZA v. STATE OF ARKANSAS" on Justia Law