Tevin Randle v. State of Arkansas, 664 S.W.3d 476

In 2018, Tevin Randle pleaded guilty to first-degree battery and unlawful possession of a firearm and received concurrent five-year terms with a sixty-month suspended imposition of sentence conditioned on no new imprisonable offenses.
The State petitioned to revoke Randle’s suspended sentence, alleging he participated in the October 21, 2021, kidnapping and transport of China Kirkland to Mississippi where she was stabbed multiple times.
Kirkland’s statements and trial testimony varied: her earlier recorded statement implicated Randle (instructing others to keep people at the house; Randle’s car used to transport her; door locked), while at the revocation hearing she downplayed his role.
At the hearing the State introduced Kirkland’s recorded prior inconsistent statement over Randle’s objection (he argued he had not been given a copy); Randle testified and denied participation but admitted prior untruths to police.
The circuit court credited the recorded statement and other evidence (locking the door, use of Randle’s car, his direction to keep people at the house, and his false statement to police) and found a probation violation by a preponderance of the evidence; Randle was sentenced to ten years’ imprisonment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether revocation was supported by a preponderance that Randle participated in or aided the kidnapping	State: Kirkland’s recorded statement and other facts show Randle facilitated restraint and transport, meeting the lower revocation standard	Randle: No evidence he restrained or intended harm; Kirkland testified he didn’t kidnap her or have a gun	Court: Affirmed revocation; credited the recorded statement, locking of the door, use of his car, and his lies to police as sufficient by preponderance
Admissibility/use of Kirkland’s prior inconsistent recorded statement	State: Recorded statement is admissible and probative in the revocation context	Randle: Statement is unsworn and only admissible for impeachment, not as substantive evidence; additionally objected the State failed to provide a copy	Court: Argument not preserved—objection below was only to lack of copy; rules of evidence are relaxed in revocation hearings, so court’s consideration was proper

Haley v. State, 240 S.W.3d 615 (2006) (appellate deference to trial court credibility findings in revocation)
Turner v. State, 538 S.W.3d 227 (2018) (kidnapping statute focuses on restraint rather than removal)
Singleton-Harris v. State, 439 S.W.3d 720 (2014) (factors to consider whether restraint supports kidnapping conviction)
McKinney v. State, 612 S.W.3d 172 (2020) (rules of evidence are not strictly applied in revocation hearings)
Stearns v. State, 529 S.W.3d 654 (2017) (false statements to police can indicate consciousness of guilt)
Eliot v. State, 27 S.W.3d 432 (2000) (requirement to make a specific objection to preserve an argument for appeal)