S.A.T. v. State, 2016 Ark. App. 469

Juvenile (appellant) was adjudicated a FINS member in 2012 and placed on formal supervision with specific conditions (school attendance, obedience to parents, cooperation with probation and treatment).
Subsequent proceedings: adjudicated delinquent in 2014 and committed to Division of Youth Services (DYS); released in 2015 with after-care conditions.
In November 2015, multiple petitions alleged new delinquency (disorderly conduct, two assaults) and violations of his prior supervision; State sought criminal contempt in the original FINS case and probation revocation in the delinquency case.
At the November 2015 consolidated hearing, the court found appellant delinquent on the new charges, revoked probation, and found him in criminal contempt, committing him to DYS for an indeterminate period.
On appeal appellant argued insufficient evidence of willful criminal contempt, but the Court of Appeals held the issue was waived because he failed to renew his motion for dismissal at the close of all evidence as required by Ark. R. Crim. P. 33.1.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for criminal contempt (willfulness)	State: evidence supported contempt finding based on violations and conduct underlying new delinquency charges	Appellant: argued there was insufficient evidence he willfully committed contempt	Waived — appellant failed to renew motion to dismiss at close of all evidence under Ark. R. Crim. P. 33.1, so sufficiency challenge not preserved

Etoch v. State, 343 Ark. 361 (strict construction of Ark. R. Crim. P. 33.1)
Thomas v. State, 315 Ark. 504 (Rule 33.1 must be strictly complied with)
McClina v. State, 354 Ark. 384 (dismissal argument made only in closing does not preserve sufficiency issue)