Travis Price v. State of Arkansas
588 S.W.3d 1
Ark.2019Background
- Late-night dice game at Mason Foster’s home; multiple guests gambling when shots were fired and Andre Eason was fatally shot.
- Eyewitnesses placed Travis Price at the scene with two younger companions; witnesses testified Price pointed a gun, demanded money, fired rounds, and fled with others.
- Police found the victim unresponsive; Price was arrested, Mirandized, and recorded; he denied involvement but invoked counsel near the end of the interview.
- Price was charged with capital murder, multiple aggravated-robbery counts, felon-in-possession, and sentencing enhancements.
- A jury convicted Price of first-degree felony murder, two counts of aggravated robbery, and a firearm enhancement; the court sentenced him as a habitual offender to life imprisonment.
- Price appealed, challenging (1) denial of directed verdicts (sufficiency of evidence), (2) use of juvenile-era violent convictions to impose habitual-offender life sentence, and (3) admission of a recorded statement that included his invocation of counsel.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence — first-degree (felony) murder | State: Eyewitness testimony and accomplice-liability theory support conviction. | Price: No witness saw him shoot the victim; evidence insufficient. | Affirmed — substantial circumstantial and eyewitness evidence supported accomplice liability and felony-murder conviction. |
| Sufficiency of evidence — aggravated robbery (Surratt) | State: Surratt’s testimony shows demand for money and theft by Price or accomplice; aggravated-robbery elements met. | Price: No proof he or his accomplice stole Surratt’s money. | Affirmed — Surratt’s account and accomplice theory supplied substantial evidence. |
| Habitual-offender life sentence using juvenile-era convictions | State: Prior violent convictions (though committed as a minor) were adjudicated in adult court and may be used to enhance sentence. | Price: Using juvenile-era convictions to impose life violates Eighth Amendment protections for juvenile offenders. | Affirmed — court followed precedent (Wilson) that juvenile convictions tried in adult court may support habitual-offender enhancement. |
| Admission of recorded statement including invocation of counsel | State: Recording and Miranda form admissible; detective properly terminated interview after Price requested counsel. | Price: Playing the recorded request for counsel (and detective’s termination) is prejudicial and violates Fifth/Sixth Amendment protections; should have been redacted/suppressed. | Denied — trial court’s admission not an abuse of discretion; no reversible prejudice shown (Justice Hart dissented, arguing Doyle/Miranda error). |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (1966) (custodial interrogation requires warnings and waiver for admissibility)
- Doyle v. Ohio, 426 U.S. 610 (1976) (post‑Miranda silence cannot be used against a defendant)
- Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life without parole for juveniles violates Eighth Amendment)
- Wilson v. State, 521 S.W.3d 123 (Ark. 2017) (juvenile convictions tried in adult court may be used to enhance sentence under habitual-offender statute)
- Gillard v. State, 372 Ark. 98 (Ark. 2008) (standard for reviewing directed‑verdict/sufficiency challenges)
- Cook v. State, 350 Ark. 398 (Ark. 2002) (accomplice-liability principles)
- Cluck v. State, 365 Ark. 166 (Ark. 2006) (circumstantial evidence must be consistent only with guilt)
- MacKool v. State, 365 Ark. 416 (Ark. 2006) (trial court’s evidentiary rulings reviewed for abuse of discretion)