Justia Criminal Law Opinion Summaries

Bellot Doucoure was convicted of three counts of raping his minor child and sentenced to life in prison. The victim testified that Doucoure raped her approximately twenty times, claiming it was required by his religion. Scientific evidence supported her testimony, with Doucoure’s DNA found on the victim’s bedsheets and the victim’s DNA on Doucoure’s underwear. The victim also testified about receiving text messages from a supposed therapist, who encouraged her to continue having sex with Doucoure. She later realized the therapist was Doucoure himself. Additional testimonies from Courtney Doucoure and Connie Stave corroborated the victim’s disclosures about the abuse.The Benton County Circuit Court, First Division, presided over the trial. The jury found Doucoure guilty on all counts. Doucoure appealed, challenging the sufficiency of the evidence and the admission of hearsay testimony. He argued that inconsistencies in the victim’s testimony and the circumstantial nature of the evidence should have led to a different verdict.The Arkansas Supreme Court reviewed the case. The court held that the victim’s testimony alone constituted substantial evidence to support the convictions, as the jury is responsible for resolving inconsistencies and assessing witness credibility. The court also found that the circuit court did not abuse its discretion in admitting limited hearsay testimony from Connie Stave. The defense had opened the door to this testimony during cross-examination, and the circuit court appropriately limited the scope of Stave’s statements.The Arkansas Supreme Court affirmed the convictions and sentences, finding no prejudicial error in the record. View "Doucoure v. State" on Justia Law

Lee Earnest Clarks, 2nd was stopped by police for running a stop sign. During the stop, the officer smelled marijuana and found marijuana, methamphetamine, and drug paraphernalia in the vehicle. A firearm was also found in a passenger’s purse. Clarks was charged with multiple felonies, including possession of methamphetamine with intent to deliver and possession of a firearm by a felon. Clarks filed a motion for discovery, including a request to preserve evidence. Upon learning that the State did not preserve video evidence from the stop, Clarks moved to dismiss the charges.The Pulaski County Circuit Court held a hearing where it was revealed that the video evidence was overwritten after 60 days due to standard police procedures. The court granted Clarks’s motion to dismiss, finding that the State’s failure to preserve the evidence amounted to bad faith. The State appealed the decision, arguing that the burden of proof was incorrectly placed on it and that the destruction of evidence was unintentional.The Supreme Court of Arkansas reviewed the case and determined that the appeal was proper for ensuring the correct administration of criminal law. The court clarified the legal standards for destruction-of-evidence cases, referencing Brady v. Maryland, California v. Trombetta, and Arizona v. Youngblood. The court held that the burden of proving a due process violation due to lost or destroyed evidence lies with the defendant. The defendant must show that the evidence had apparent exculpatory value before its destruction and that comparable evidence could not be obtained by other means. Additionally, if the evidence is only potentially useful, the defendant must prove that the State acted in bad faith.The Supreme Court found that the circuit court erred in its application of the law by shifting the burden of proof to the State and by equating unintentional destruction of evidence with bad faith. The court reversed the circuit court’s decision and remanded the case for further proceedings. View "STATE OF ARKANSAS v. CLARKS" on Justia Law

In August 2020, Timothy Wayne Ross was accused of sexually abusing his eleven-year-old step-granddaughter. The abuse included inappropriate touching, showing her a pornographic video, and making her touch him. Ross was charged with rape, second-degree sexual assault, and sexually grooming a child. His trial took place on February 27-28, 2023, in the Dallas County Circuit Court. Ross was present on the first day but failed to appear on the second day, despite assurances to his counsel that he would attend. Efforts to locate him were unsuccessful, and the trial proceeded in his absence.The Dallas County Circuit Court jury found Ross guilty on all charges, sentencing him to life imprisonment for rape, twenty years for second-degree sexual assault, and six years for sexually grooming a child, to be served concurrently. Ross's counsel did not initially object to proceeding without him but later moved for a continuance due to Ross's absence and the unavailability of a key witness, which the court denied. Ross was eventually located and brought back for sentencing.The Arkansas Supreme Court reviewed the case, focusing on whether the trial court abused its discretion by proceeding in Ross's absence. Ross argued that his absence was not voluntary and that the trial should not have continued without him. However, the Supreme Court noted that Ross's counsel did not raise this specific argument at trial, instead focusing on the need for a continuance due to Ross's unavailability. As a result, the Supreme Court held that Ross's argument was not preserved for appeal and affirmed the lower court's decision. The court also reviewed the record for any other errors and found none. View "Ross v. State" on Justia Law

In 2017, a jury in Pope County convicted Tyler Joseph Barefield of two counts of capital murder for the premeditated killings of Aaron Brock and Beau Dewitt. Barefield was sentenced to life without parole for each count and received an additional 180-month term for using a firearm in the commission of the murders. The murders occurred after Barefield, suspecting trespassers at his salvage yard, lay in wait with a rifle and ambushed Brock and Dewitt. Their bodies were later found crushed in vehicles at the salvage yard. Barefield's convictions were affirmed on direct appeal.Barefield subsequently filed a petition for postconviction relief under Rule 37 of the Arkansas Rules of Criminal Procedure, alleging ineffective assistance of counsel. The Pope County Circuit Court denied the petition, adopting the State’s proposed findings of fact and conclusions of law. Barefield appealed this decision, arguing that his trial counsel’s performance was deficient and prejudicial.The Supreme Court of Arkansas reviewed the case and applied the two-step analysis from Strickland v. Washington, which requires showing that counsel’s performance was deficient and that the deficiency prejudiced the defense. The court found that Barefield’s claims were unsubstantiated and conclusory. It held that decisions regarding trial strategy, such as not consulting a ballistics expert or not seeking a mistrial for prosecutorial statements, fell within the realm of reasonable professional judgment. The court also upheld the circuit court’s decision to exclude Colonel Arthur Alphin’s testimony on the victims’ cause of death, as Alphin was not a qualified medical expert.The Supreme Court of Arkansas affirmed the Pope County Circuit Court’s denial of postconviction relief, finding no clear error in its judgment. View "BAREFIELD v. STATE OF ARKANSAS" on Justia Law

Sir Jeffery McNeil-Lewis was convicted of first-degree murder, first-degree battery, eight counts of terroristic threatening, and firearm enhancements, resulting in a life sentence plus fifteen years. The convictions stemmed from a shooting at an abandoned house in West Memphis, where McNeil-Lewis and an accomplice fired at Jarvis Moore and Stacy Abram. Moore died, and Abram survived, identifying McNeil-Lewis as a shooter. Additional evidence, including eyewitness testimony and gunshot residue, linked McNeil-Lewis to the crime.The Crittenden County Circuit Court denied McNeil-Lewis's petition for postconviction relief under Rule 37, which claimed ineffective assistance of counsel. The court found that McNeil-Lewis failed to prove both deficient performance by his counsel and resulting prejudice. Specific claims included strategic decisions not to object to 911 calls on hearsay grounds, not to pursue self-defense, and not to object during sentencing. The court also found no prejudice from the failure to suppress evidence or from juror misconduct, as no actual bias was shown. Additionally, the court ruled that a Batson challenge would have been meritless and that not calling witnesses during sentencing was a strategic decision. Lastly, the court credited defense counsel's testimony that McNeil-Lewis was informed of and rejected a plea offer.The Arkansas Supreme Court affirmed the circuit court's judgment, finding no clear error in its conclusions. The court held that McNeil-Lewis's arguments on appeal did not adequately address the circuit court's findings, particularly regarding strategic decisions and lack of prejudice. The court also upheld the circuit court's credibility determinations and strategic decisions made by defense counsel, concluding that McNeil-Lewis failed to meet the burden of proving ineffective assistance of counsel. View "MCNEIL-LEWIS v. STATE OF ARKANSAS" on Justia Law

Christopher Segerstrom was convicted of capital murder for the 1986 killing of a four-year-old and was initially sentenced to life imprisonment without parole. He was 15 years old at the time of the crime. Following the U.S. Supreme Court's decision in Miller v. Alabama, which prohibits mandatory life without parole for juvenile offenders, Segerstrom's sentence was vacated and remanded for resentencing. The Washington County Circuit Court resentenced him to life with the possibility of parole after thirty years without a hearing, which was reversed by the Arkansas Supreme Court, mandating a hearing to consider mitigating factors.Upon remand, Segerstrom's fitness to proceed was contested. The circuit court initially found him unfit due to schizophrenia but later deemed him fit after a year of treatment, based on a forensic evaluation by Dr. Melissa Wright. Segerstrom's defense presented conflicting expert testimony, but the court credited Dr. Wright's findings. On the day of the resentencing hearing, Segerstrom's counsel requested a continuance, claiming he was unresponsive due to medication, which the court denied.During the resentencing, the court admitted prior testimony from Dr. Joseph Halka, who performed the autopsy, over Segerstrom's objection. The court also rejected a nonmodel jury instruction proposed by Segerstrom, which emphasized the differences between juvenile and adult offenders as per Miller. The jury ultimately sentenced Segerstrom to life imprisonment.The Arkansas Supreme Court affirmed the circuit court's decisions, holding that substantial evidence supported the finding of Segerstrom's fitness to proceed, the denial of the continuance was not an abuse of discretion, the admission of Dr. Halka's testimony was proper, and the rejection of the proposed jury instruction was appropriate given the sentencing options. View "SEGERSTROM V. STATE OF ARKANSAS" on Justia Law

Bobby Wyles was convicted of two counts of capital murder for killing Susie Fuller and Jerry Drinkwater in the presence of two children. The incident occurred on January 5, 2019, at the victims' home, where Wyles, Fuller, and Drinkwater were using drugs. An argument ensued, leading Wyles to stab Fuller and Drinkwater multiple times, resulting in their deaths. Fuller was stabbed thirty-two times, and Drinkwater twenty-eight times. Wyles claimed he was in a blacked-out state of rage due to drug use and alleged sexual assault by Drinkwater. Eyewitness testimony and DNA evidence supported the prosecution's case.The Perry County Circuit Court denied Wyles's motions for a directed verdict, and a jury found him guilty of capital murder. Wyles was sentenced to two consecutive life sentences without parole, plus two five-year sentences for the presence-of-a-child enhancements. Wyles appealed, arguing that he lacked the culpable mental state for capital or first-degree murder.The Arkansas Supreme Court reviewed the case, focusing on whether substantial evidence supported the capital murder convictions. The court noted that premeditation and deliberation could be inferred from the circumstances, such as the nature and extent of the wounds and the conduct of the accused. The court found that the evidence, including the number and nature of the stab wounds and the prolonged struggle, supported the jury's conclusion of premeditation and deliberation. The court affirmed the circuit court's denial of Wyles's directed-verdict motion and upheld the capital murder convictions. The court also reviewed the record for any prejudicial errors and found none. The Arkansas Supreme Court affirmed the convictions and sentences. View "Wyles v. State" on Justia Law

The case revolves around Corey Jeffery, who was convicted of capital murder and first-degree unlawful discharge of a firearm from a vehicle by the Arkansas County Circuit Court. The victim, Christopher Haynes, was found dead in his car at his workplace, Riceland Foods plant. The investigation led to the identification of a Dodge Ram truck, distinctive in its features, which was likely involved in the homicide. Jeffery and Jonathan Dabner were identified as suspects, with Dabner pleading guilty in a separate case to unlawful discharge of a firearm from a vehicle. Evidence against Jeffery included a .40-caliber Smith & Wesson bullet found in the truck, a receipt for the purchase of a .40-caliber handgun and ammunition, and video footage of Jeffery and Dabner at the gun store. Jeffery's wife testified about an alleged affair between her and the victim, which had caused friction in their marriage.The trial court denied Jeffery's motions for directed verdict, and the jury convicted him of capital murder and first-degree unlawful discharge of a firearm from a vehicle. He was sentenced to life imprisonment plus seventy years with an enhancement of fifteen years on each count for committing a felony with a firearm. Jeffery appealed, arguing that the circuit court erred in denying his motions for directed verdict, claiming that the State failed to present substantial evidence that he committed the offenses.The Supreme Court of Arkansas affirmed the lower court's decision. The court found substantial evidence supporting the convictions, including Jeffery's access to a .40-caliber handgun, his presence at the crime scene, and his attempt to silence a witness. The court concluded that the jury could have reached a conclusion with reasonable certainty, without resorting to speculation or conjecture, that Jeffery discharged a firearm from a vehicle, causing Haynes's death under circumstances manifesting extreme indifference to the value of human life. View "Jeffery v. State" on Justia Law

The case revolves around Raymond Bailey, a probationer who signed a waiver allowing law enforcement to conduct warrantless searches of his person, residence, and vehicle. In June 2020, North Little Rock Police observed Bailey engaging in suspicious activities indicative of illegal drug transactions. They discovered that Bailey was on probation and had signed a search waiver. Upon detaining Bailey, they found a key to a motel room, which they subsequently searched, finding heroin and drug paraphernalia. Bailey was charged, but he moved to suppress the evidence, arguing that the police did not have probable cause to believe that the motel room was his residence.The Pulaski County Circuit Court granted Bailey's motion to suppress, ruling that law enforcement must have probable cause to believe that the place to be searched is the probationer's residence. The court found that the police did not have probable cause to believe that the motel room was Bailey's residence, and therefore, the warrantless search violated the Fourth Amendment. The State of Arkansas appealed this decision.The Supreme Court of Arkansas disagreed with the lower court's ruling. The Supreme Court held that the correct legal standard requires law enforcement to have a reasonable suspicion, based on the totality of the circumstances, to believe the place to be searched is the probationer's residence if conducting a search under that provision. The court found that the police had a reasonable suspicion that Bailey was residing in the motel room, making the search permissible under the statute and consistent with the Fourth Amendment. Therefore, the Supreme Court reversed the decision to suppress the evidence and remanded the case back to the circuit court. View "STATE OF ARKANSAS v. BAILEY" on Justia Law

The case revolves around Maurice Richardson, who was convicted of second-degree murder, rape, and abuse of a corpse. The victim, Tonia Tran, was found suffocated to death, severely beaten, and with vaginal injuries. Evidence linked Richardson to the crime, including Tran's blood found in his bedroom and her car, her body wrapped in a bedspread matching pillow shams from his home, and a cigarette butt with his DNA near her body. Richardson had initially denied his relationship with Tran but later admitted to living with her and having sex recently. However, he denied involvement in the murder.Richardson was initially charged with first-degree murder, rape, and abuse of a corpse. He moved for a directed verdict on all charges, arguing insufficient evidence to prove he caused Tran's death, that Tran was alive during the sexual activity, or that it was done for sexual gratification. He also argued that there was no evidence he knowingly mistreated or concealed a corpse in an offensive manner. The circuit court denied the motions, and the jury convicted him of second-degree murder, rape, and abuse of a corpse. He was sentenced as a habitual offender to sixty years’ imprisonment, life imprisonment, and thirty years’ imprisonment, respectively.In the Supreme Court of Arkansas, Richardson argued that insufficient evidence supported his murder and rape convictions. The court, viewing the evidence in the light most favorable to the verdict, found substantial evidence to support the convictions. The court noted that Richardson's DNA was found near Tran's body, her blood was found in his bedroom and her car, and her body was wrapped in bedding matching items from his home. The court also noted Richardson's attempts to conceal the crime, including moving a blood-stained mattress and Tran's belongings, buying new bedding, and lying about his relationship with Tran. The court affirmed the lower court's decision. View "Richardson v. State" on Justia Law