Schnarr v. State
2017 Ark. 10
Ark.2017Background
- On May 11, 2013, Chris Aaron Schnarr (a concealed-carry permit holder) shot and killed Arista Aldridge after a road‑rage confrontation; Schnarr admitted firing three shots, one fatal to the abdomen.
- Schnarr testified Aldridge approached, poked him, and he fired when Aldridge advanced; Schnarr denied seeing a weapon or hearing threats.
- Schnarr was tried for first‑degree murder; the court instructed on lesser included offenses (second‑degree murder, manslaughter) and justification (self‑defense). The jury convicted Schnarr of manslaughter and sentenced him to ten years.
- Schnarr appealed, arguing the trial court erred by (1) excluding evidence of Aldridge’s prior violent acts unknown to Schnarr, (2) refusing a mistrial after the bailiff excluded family members from voir dire, and (3) refusing instructions on negligent homicide and imperfect self‑defense.
- The Arkansas Supreme Court affirmed the evidentiary rulings and the denial of lesser‑offense instructions, but held the partial courtroom closure during nearly all of voir dire violated Schnarr’s public‑trial right and ordered a new trial.
Issues
| Issue | Plaintiff's Argument (Schnarr) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Admissibility of victim’s prior violent acts unknown to defendant | Evidence of Aldridge’s domestic‑violence incidents against his girlfriend was admissible to support justification and to show Aldridge was aggressor | Prior‑acts evidence of the victim is limited by AR Evid R 404/405; when offered to show defendant’s state of mind, specific acts are admissible only if defendant knew of them | Exclusion was proper: for state‑of‑mind purpose, specific‑instance proof requires the defendant’s prior knowledge; no constitutional violation in excluding evidence Schnarr did not know |
| Violation of public‑trial right during voir dire | Bailiff excluded family members from courtroom during jury selection; Schnarr moved to quash jury and for mistrial when he learned of exclusion | Any exclusion was inadvertent and partial; presence of others (press, attorney) shows courtroom was not closed; State disputed preservation | Reversible error: exclusion of three family members for ~2.5 hours (most of voir dire) constituted a non‑trivial partial closure of voir dire; new trial ordered |
| Instruction on negligent homicide | Schnarr sought negligent‑homicide instruction as a lesser offense if his belief in necessity of force was negligent | Shooting was intentional (three shots at close range); no evidence defendant was unaware risk of fatality; negligent homicide not supported | No rational basis for negligent‑homicide instruction; refusal not an abuse of discretion |
| Instruction on imperfect self‑defense (Ark. Code §5‑2‑614) | Schnarr argued jury should be instructed that an unreasonable or negligent belief in necessity could negate murder and support lesser offense | No evidence Aldridge threatened or brandished a weapon; no basis to find recklessness/negligence in belief of imminent deadly force | Court declined instruction: facts did not present rational basis for imperfect self‑defense instruction; refusal upheld |
Key Cases Cited
- Presley v. Georgia, 558 U.S. 209 (2010) (Sixth Amendment public‑trial right applies to jury selection)
- Waller v. Georgia, 467 U.S. 39 (1984) (public‑trial values and that closure need not show prejudice)
- In re Oliver, 333 U.S. 257 (1948) (public trial as safeguard against secret proceedings)
- Montague v. State, 213 Ark. 575 (1948) (Arkansas rule limiting victim‑character proof to reputation/opinion when offered to show aggressor)
- Pope v. State, 262 Ark. 476 (1977) (specific‑instance evidence admissible to show accused’s knowledge and state of mind only if accused knew of those acts)
- Harshaw v. State, 344 Ark. 129 (2001) (discussing imperfect self‑defense and when negligent belief can support lesser instruction)
- Holmes v. South Carolina, 547 U.S. 319 (2006) (states may exclude evidence under rules that are not arbitrary or disproportionate)