Stevenson v. State
2013 Ark. 100
| Ark. | 2013Background
- Stevenson was convicted of first-degree murder and sentenced to life; on appeal he challenges multiple trial rulings.
- The victim, Michael Fox, died from three stab wounds with blood loss and collapsed lung as primary cause.
- Stevenson lived with Fox and Fox’s mother Atchley; knives and a knife box were found near the scene, box lid and bottom located.
- Stevenson admitted fighting Fox; evidence showed blood on his shirt and shoe; a knife box and related items connected him to the weapon.
- Stevenson argued the trial court should have granted a directed verdict, suppressed his statement after invoking counsel, granted mistrial, and excluded prior bad acts and a knife cast.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence | Stevenson contends no basis for guilt. | State failed to prove guilt beyond reasonable doubt. | Substantial evidence supports murder verdict. |
| Suppression of statement after right to counsel | Stevenson invoked counsel; interrogation continued unlawfully. | Interrogation did not seek incriminating response; no clear violation. | No error in denying suppression; did not clearly violate Edwards standard. |
| Mistrial due to opening statement mentioning right to counsel | Mention of invoking counsel prejudiced trial; warrants mistrial. | Curative instruction sufficed; no prejudice showed. | No mistrial required; curative instruction adequate. |
| Admission of prior bad acts under Rule 404(b) | Prior knife incidents show intent; probative relevance. | Prior acts lack substantial similarity and mislead jury. | Admission not reversible; evidence held admissible to show intent and knowledge. |
| Plaster cast of knife as evidence | Cast supports identification of weapon. | Cast is prejudicial; probative value minimal. | No abuse of discretion; cast properly admitted. |
Key Cases Cited
- Edwards v. Arizona, 451 U.S. 477 (U.S. Supreme Court 1981) (right to counsel must be available; no interrogation after request)
- Rhode Island v. Innis, 446 U.S. 291 (U.S. Supreme Court 1980) (interrogation includes words or actions likely to elicit an incriminating response)
- Doyle v. Ohio, 426 U.S. 610 (U.S. Supreme Court 1976) (unwarned or uncounseled silence can't be used to impeach testimony)
- Holden v. State, 290 Ark. 458 (Ark. Supreme Court 1986) (opening statement mentioning invocation of counsel not always reversible error)
- Jarreau v. State, 291 Ark. 60 (Ark. Supreme Court 1987) (miranda rights and impeachment considerations in Arkansas)
- Osburn v. State, 2009 Ark. 390 (Ark. Supreme Court 2009) (right to counsel during custodial interrogation; Edwards/Innis framework applied)
- Anderson v. State, 2011 Ark. 461 (Ark. Supreme Court 2011) (sufficiency review; substantial evidence standard)
- Rollins v. State, 362 Ark. 279 (Ark. Supreme Court 2005) (Rule 404(b) independently relevant evidence standard)
- McGehee v. State, 338 Ark. 152 (Ark. Supreme Court 1999) (high similarity requirement for 404(b) evidence)