Hoyle v. State, 388 S.W.3d 901

After a jury trial, Hoyle was convicted of two counts of manslaughter and one count of first-degree battery and sentenced to 120 months on each manslaughter count and 240 months on the battery, for a total of 480 months.
This Court previously affirmed the judgment against Hoyle in 2007.
Hoyle, represented by counsel, filed a Rule 37.1 petition asserting ineffective assistance of counsel on multiple grounds.
The trial court conducted a hearing, issued written findings, and denied relief on all claims.
On appeal, Hoyle reasserts five ineffective-assistance claims related to plea negotiations, hearsay objections, information amendment, prior-bad-acts evidence, and a request for sentence reduction.
The court applies the Strickland standard, reviewing the two-prong test for deficient performance and prejudice, under a highly deferential standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Effect of counsel on plea negotiations	Hoyle argues counsel failed to advocate a withdrawn plea or explain amended terms.	State contends counsel conveyed all offers and Hoyle rejected them; no prejudice shown.	denial affirmed; no error in counsel's conduct
Objection to hearsay	Hoyle claimed counsel should have objected to hearsay testimony in sentencing.	State maintains the decision was trial strategy and not error.	denial affirmed; strategy supported by evidence
Objecting to amendment of information	Hoyle asserts prejudice from amended information altering charges.	State contends amendment did not change the offense and any prejudice would be avoided by procedural rules.	denial affirmed; no reversible error or prejudice
Prior bad acts evidence	Hoyle claims counsel should have objected to sentencing evidence of prior arrest.	State argues strategic decision allowed probative value for sentencing.	denial affirmed; trial strategy supported by reasonable judgment
Motion to reduce sentence	Hoyle asserts counsel should have moved to reduce the jury-imposed sentence which was unduly harsh.	State contends reduction would have been denied and the court could sua sponte reduce under statute.	denial affirmed; no showing of reversible error

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes two-prong test for ineffective assistance)
Croy v. State, 383 S.W.3d 367 (Ark. 2011) (Strickland standard applied; per curiam)
Anderson v. State, 373 S.W.3d 876 (Ark. 2010) (totality-of-the-evidence approach to IAC)
Miller v. State, 2011 WL 913206 (Ark. 2011) (per curiam on IAC standards)
Carter v. State, 2011 WL 1896765 (Ark. 2011) (prejudice showing under Strickland)
Mingboupha v. State, 2011 WL 1805339 (Ark. 2011) (reasonable probability standard for prejudice)
Phavixay v. State, 352 S.W.3d 311 (Ark. 2009) (amendment-notice prejudice standard)
Terry v. State, 263 S.W.3d 528 (Ark. 2007) (information amendment and prejudice considerations)
Mitchem v. State, 2011 WL 1319579 (Ark. 2011) (trial-strategy considerations in hearsay objections)
Rush v. State, 919 S.W.2d 933 (Ark. 1996) (hearsay admissibility and sentencing evidence context)
Brown v. State, 378 S.W.3d 66 (Ark. 2010) (statutory authority to reduce sentence; discretion to deny)
Thomas v. State, 79 S.W.3d 347 (Ark. 2002) (judge may reduce sentence sua sponte)
Noland v. State, 580 S.W.2d 953 (Ark. 1979) (good-cause-dismissal considerations in dismissals on eve of trial)
Crawford, 281 S.W.3d 736 (Ark. 2008) (good-cause and speedy-trial considerations)