James v. State
2010 Ark. 486
| Ark. | 2010Background
- Appellant Robert James was convicted of first-degree murder and sentenced to life imprisonment for killing Tony Rice.
- Counsel representing James on appeal filed a motion to withdraw and a no-merit Anders brief; James submitted pro se points.
- Evidence showed James had knowledge of Heather Rice's affair with Tony Rice, investigated the affair, and shot Rice after arriving at the Walmart parking lot where they worked.
- Video evidence showed James blocking Rice's truck, firing multiple shots, pursuing Rice, and delivering a final shot, followed by James concealing the weapon and writing a note to Heather.
- Police testified James admitted to shooting Rice; medical examiner attributed Rice’s death to two gunshot wounds to the face.
- The court granted counsel’s motion to withdraw, affirmed the conviction, and held that the trial rulings were not error.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for first-degree murder | James had not shown the required purposeful intent. | Evidence showed emotional reaction rather than the requisite intent. | Substantial evidence supports first-degree murder; intent may be inferred from circumstances. |
| Limitation on extramarital affair evidence | Evidence of the affair is irrelevant and prejudicial; no defense would justify it. | Affair evidence relevant to James's state of mind and defense theory. | Trial court properly allowed defense development and limited cross-examination; not reversible. |
| Admission of handwritten note and notice | Note admission violated best evidence or notice requirements. | Defense had notice; photographs/readability issues cured by later disclosure. | Appellant waived further objection; no reversible error. |
| Rebuttal testimony by Bonnie Balasco | Rebuttal testimony properly responsive to defense theory. | Balasco could not rebut her own prior testimony; improper. | Rebuttal proper; testimony admissible to respond to new matters raised by defense. |
| Golden rule closing argument objection | Defense objected to urging jurors to place themselves in witness's or victim's position. | Admonition given was adequate; no reversible error. | Even if error, defense expressed satisfaction with admonishment; not reversible. |
Key Cases Cited
- Strong v. State, 372 Ark. 404 (2008) (directed-verdict review requires sufficiency analysis)
- Leaks v. State, 345 Ark. 182 (2001) (intent may be inferred from circumstantial evidence)
- Robinson v. State, 353 Ark. 372 (2003) (state of mind inferred from crime circumstances)
- Holloway v. State, 363 Ark. 254 (2005) (cross-examination breadth and agreement on evidence)
- Ward v. State, 370 Ark. 398 (2007) (preservation and review limits on objections)
- Davlin v. State, 313 Ark. 218 (1993) (jury communications and compliance with statute)
- Jackson v. State, 375 Ark. 321 (2009) (peremptory challenges, not reviewable on appeal)
- Eubanks v. State, 2009 Ark. 170 (2009) (preliminary evidentiary rulings require prejudice showing)
- Christian v. State, 318 Ark. 813 (1994) (preservation of appeal and renewal of motions)
- Davis v. State, 2009 Ark. 478 (2009) (insanity defense evidence; jury resolution)
- Taylor v. State, 2010 Ark. 372 (2010) (waiver and appellate argument standards)