2015 Ark. 229
Ark.2015Background
- In 1982 McDaniel and a co-defendant were convicted of capital murder by a jury.
- In 1983 this court reversed and remanded for separate trials.
- Gookin pleaded guilty to second-degree murder in 1983 and testified for the prosecution at McDaniel’s retrial.
- McDaniel was found guilty of first-degree murder at the retrial and sentenced to life imprisonment.
- In 2014 McDaniel filed pro se petitions to proceed in forma pauperis and for production of transcripts, seeking the Gookin plea hearing transcript.
- He claimed the transcript would show exculpatory evidence Brady withheld, allegedly undermining his trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Entitlement to transcripts at public expense | McDaniel argues he has good cause under Rule 72 for public transcription. | State contends indigency alone is insufficient; no compelling need shown for free transcripts. | Affirmed; no compelling need shown; indigence alone insufficient. |
Key Cases Cited
- Meek v. State, 2013 Ark. 314 (Ark. 2013) (indigency alone does not require free photocopying)
- Anthony v. State, 2014 Ark. 195 (Ark. 2014) (compelling need required for public expense transcripts in postconviction matters)
- Woodruff v. State, 313 Ark. 585 (Ark. 1993) (courts consider arguments actually raised below; scope limited to trial court ruling)