Watson v. State
2014 Ark. 203
| Ark. | 2014Background
- Watson was convicted of capital murder in Pulaski County; the death penalty was waived, yielding life imprisonment without parole.
- Watson filed a January 16, 2013 Rule 37.1 postconviction petition alleging ineffective assistance of trial and appellate counsel; the circuit court denied relief on April 22, 2013 without a hearing.
- Evidence showed Harris died from blunt-force trauma with a concrete piece; Watson was last seen with Harris and confessed to several people that he killed someone.
- Key witnesses included Sara Whipple (Watson at 3:00 a.m., scratches and blood on him), Marcus Hildreth (Watson admitted striking Harris with a rock), and others who placed Watson at or near the scene or after the murder, supporting guilt.
- The court applied Strickland v. Washington two-prong standard for ineffective assistance, emphasizing totality of the evidence and presumption of competent counsel; it affirmed the circuit court’s denial of Rule 37.1 relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial counsel's investigation failures prejudiced Watson | Watson (Watson) argues failure to investigate Allen Boyd for motive. | State contends allegations lack factual substantiation and prejudice cannot be shown. | No prejudice; allegations are conclusory and insufficient. |
| Whether trial counsel was ineffective for not pursuing Whipple's mental health/competence evidence | Watson claims counsel should have challenged Whipple’s competence or sought mental evaluation. | Circuit court found no support that competency would alter outcome; grounds not raised in petition. | Not warranted; argument differently framed on appeal does not change the outcome. |
| Whether trial counsel was ineffective for not objecting to closing remarks about the DNA sample | Watson contends prosecutor framed right to remain silent and DNA testing as incriminating. | Fifth Amendment does not apply to DNA testing or demonstrative tests; remarks based on trial testimony. | No error; objections would not have been meritorious. |
| Whether appellate counsel was ineffective for not challenging sufficiency of the evidence | Watson argues sufficiency preserved and trial moved for directed verdict. | Appellate counsel need not advance every argument; sufficiency review favors the State. | Appellate counsel not ineffective; evidence was substantial and supported verdict. |
| Whether Martinez/Trevino require appointment of counsel in postconviction proceedings | Watson invokes Martinez and Trevino to claim counsel should be appointed. | Issue not preserved; Paige v. State commentary indicates no automatic appointment on appeal. | Issue not preserved; not addressed on the merits. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (Supreme Court, 1984) (two-prong standard for ineffective assistance of counsel)
- Conley v. State, 2014 Ark. 172 (Ark. Supreme Court, 2014) (standard for reviewing postconviction claims of ineffectiveness)
- Williams v. State, 2011 Ark. 489 (Ark. Supreme Court, 2011) (burden to show deficient performance)