Linell v. State, 565 S.W.3d 482

Carl Lee Linell was convicted in 1983 of two counts of capital murder and one count of attempted murder; sentenced to two life terms without parole plus 20 years consecutive.
In October 2015 Linell requested that Jefferson County Prosecuting Attorney S. Kyle Hunter authorize the Arkansas State Crime Lab to release records and documents related to his 1983 trial, specifically testimony about a pistol allegedly belonging to James Nelson.
Prosecutor Hunter denied authorization; Linell filed a petition for a writ of mandamus in June 2016 asking the circuit court to order disclosure from the crime lab.
The circuit court denied the petition; Linell appealed, arguing Ark. Code Ann. § 12-12-312 and Davis v. Deen entitled him to full access to his crime-lab records and that the prosecutor must authorize release.
The State argued § 12-12-312(a)(1)(B)(ii) requires the prosecutor to disclose only upon discovering evidence retained by the lab that tends to negate guilt or reduce punishment, and that the requested records here did not meet that threshold.
The Arkansas Supreme Court affirmed, holding mandamus inappropriate because the prosecutor’s duty to disclose under the statute is triggered only when the prosecutor discovers evidence that tends to negate guilt or reduce punishment, a non‑ministerial obligation Linell failed to show had arisen.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Linell had a clear, enforceable right to compel the prosecutor to authorize release of crime-lab records via mandamus	Linell: § 12-12-312 and Davis guarantee a defendant "full access" to all records pertaining to his case and obligate the prosecutor to permit release upon request	State: § 12-12-312(a)(1)(B)(ii) only mandates prosecutor disclosure when the prosecutor discovers evidence that tends to negate guilt or reduce punishment; otherwise authorization is discretionary	Court: Denied mandamus — prosecutor’s disclosure duty is not ministerial and is triggered only upon discovery of evidence tending to negate guilt or reduce punishment; Linell did not show a clear right to relief
Whether the statutory phrase "full access to all records" eliminates need for crime-lab authorization or prosecutor action	Linell: The statute and Davis mean a defendant may obtain his crime-lab records without prosecutor or court authorization	State: The statute’s disclosure duty is separate; authorization/discretion remains for public release and the prosecutor’s affirmative duty applies only to exculpatory evidence he discovers	Court: Agreed that defendants retain a right to access records, but refused mandamus because the remedy sought targeted the prosecutor’s discretionary/affirmative duties rather than a ministerial custodian duty

Davis v. Deen, 437 S.W.3d 694 (Ark. 2014) (recognized defendant's right to receive crime-lab information developed in his case)
Pritchett v. Spicer, 513 S.W.3d 252 (Ark. 2017) (mandamus requires showing a clear and certain right and absence of other adequate remedy)
Dobbins v. Democratic Party of Ark., 288 S.W.3d 639 (Ark. 2008) (standard of review for mandamus denial is abuse of discretion)
Ark. Dep't of Corr. v. Shults, 529 S.W.3d 628 (Ark. 2017) (FOIA exemptions interpreted narrowly to favor disclosure)
Jones v. State, 64 S.W.3d 728 (Ark. 2002) (court may affirm on a correct result even if for wrong reasoning)