Reynolds v. State, 2016 Ark. 214

Victim Rachel Wake was bound with cables and padlocks, gagged, beaten, and threatened with death by her boyfriend Edward Reynolds; ligature marks, bruising, fractures, and blood evidence tied to Reynolds’ home were found.
Michael Watters (Reynolds’s friend) witnessed parts of the assault, confirmed bindings and threats, and later testified for the State after pleading guilty to a related charge.
Police seized cables and locks from Reynolds’s residence; DNA matched Wake; photos and hospital records documented injuries including concussion and fractures.
Reynolds was convicted by a jury of kidnapping (purpose: terrorize) and aggravated assault (extreme indifference creating substantial danger of death/serious injury) and sentenced as a habitual offender to consecutive life and 15-year terms.
On appeal Reynolds challenged (1) denial of directed-verdict motions as to both charges, (2) allowance of Wake’s testimony about injuries despite alleged discovery failures, and (3) overruling his objection to prosecutor remarks in closing.
The Arkansas Supreme Court affirmed, finding sufficient evidence, waiver of some objections for failure to contemporaneously object, and no reversible prosecutorial error (majority); a concurrence found the vouching improper but harmless given overwhelming evidence.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Reynolds)	Held
Sufficiency for kidnapping (purpose to terrorize)	Evidence showed restraint, threats, injuries, and discussions to dispose of body — supports conviction	Restraints were later removed, Reynolds aided bathing, and Wake did not immediately escape — undermines terrorizing purpose	Aff’d — substantial evidence supports kidnapping conviction
Sufficiency for aggravated assault (purpose; extreme indifference)	Beating while bound, ligature-induced choking risk, severe injuries, and death threats show purposeful conduct and extreme indifference	Drug use negated purposeful intent; insufficient life‑threatening activity	Aff’d — issue of drug-induced lack of purpose not preserved; evidence supports aggravated assault
Admission of victim’s testimony about medical injuries (discovery)	Testimony was admissible and cumulative of earlier testimony; no contemporaneous objection so issue waived	Failure to produce medical records prejudiced defense	Waived/harmless — no contemporaneous objection; later testimony was cumulative
Prosecutor’s closing remarks (vouching)	Comments were argument, not evidence; trial court gave curative instruction	Prosecutor vouched for witness and impermissibly placed State’s credibility behind victim	Aff’d (majority): no abuse of discretion; curative instruction sufficient. Concurrence: remarks improper vouching but harmless given overwhelming evidence

Williamson v. State, 350 S.W.3d 787 (Ark. 2009) (standard for reviewing directed‑verdict/sufficiency challenges)
Ridling v. State, 203 S.W.3d 63 (Ark. 2005) (fact‑finder credibility and weighing evidence principles)
Conte v. State, 463 S.W.3d 686 (Ark. 2015) (contemporaneous‑objection rule and waiver doctrine)
Jefferson v. State, 276 S.W.3d 214 (Ark. 2008) (trial court discretion over closing arguments; expressions of opinion not reversible absent prejudice)
Neff v. State, 696 S.W.2d 736 (Ark. 1985) (limits on counsel injecting personal beliefs in argument)
Parker v. State, 578 S.W.2d 206 (Ark. 1979) (broad latitude for trial judge supervising arguments; mistrial relief rarely warranted)
United States v. Young, 470 U.S. 1 (U.S. 1985) (prosecutorial vouching and standard for improper prosecutorial conduct)