2014 Ark. App. 671
Ark. Ct. App.2014Background
- Arkansas Court of Appeals Division II, No. CR-11-415, appellate review of Edward Anthony Liggins's conviction and sentence.
- Jury convicted Liggins of first-degree murder and first-degree battery; murder sentence 40 years plus 15-year firearm enhancement and 10-year child-present enhancement, all consecutive (65 years total); battery 20 years, running concurrent to the 65-year sentence.
- Probation on underlying offense revoked; not an issue on appeal.
- Liggins moved for a new trial; motion denied; timely notice of appeal filed.
- Court ordered rebriefing due to deficiencies in Liggins’s abstract, addendum, and brief; counsel Teresa Bloodman relieved; Robby Golden appointed for representation on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did victim-impact testimony during penalty phase require mistrial? | Liggins | Liggins | Merits not reached; due to brief deficiencies, merits not decided. |
| Did voir dire instruction readings by counsel/prosecutor require correction? | Liggins | Liggins | Merits not reached; due to brief deficiencies, merits not decided. |
| Was Liggins denied counsel of choice/continuance to enter appellate counsel appearance? | Liggins | Liggins | Merits not reached; due to brief deficiencies, merits not decided. |
| Did trial court improperly compel continued representation after self-representation request? | Liggins | Liggins | Merits not reached; due to brief deficiencies, merits not decided. |
| Was trial counsel deficient and did that justify new-trial relief? | Liggins | Liggins | Merits not reached; due to brief deficiencies, merits not decided. |
Key Cases Cited
- Liggins v. State, 2012 Ark. App. 555 (Ark. App. 2012) (rebriefing deficiencies in prior appeal cited by court)
- Liggins v. State, 2014 Ark. App. 181 (Ark. App. 2014) (prior appeal noted for deficiencies leading to rebriefing)