Williams v. State
2015 Ark. App. 245
Ark. Ct. App.2015Background
- Consolidated appeal from Williams’s convictions in case 12-1651 for possession with purpose to deliver, drug paraphernalia, and maintaining a drug premises; total 840 months’ imprisonment after consecutive sentences.
- Probation revocation in case 08-1708 resulted in a cumulative 80-year sentence when consecutive to case 12-1651.
- Pre-trial stipulations barred evidence of pre-warrant information unless defense opened the door.
- During trial, Detective Littleton testified to the search warrant basis and pre-warrant conduct; the defense argued the door was not opened.
- Cross-examination focused on post-warrant evidence (cocaine in pocket, scales); the State argued the door was opened, trial court ruled accordingly.
- The trial court denied motions for directed verdict; jury convicted on all charges; revocation hearing followed immediately, leading to post-trial appellate issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court abused its discretion in allowing pre-warrant testimony to the warrant’s basis | Williams (State) argues defense opened the door. | Williams contends defense did not open the door to pre-warrant evidence. | Abuse of discretion; reversed and remanded for new trial in case 12-1651. |
| Whether probation revocation was supported by the evidence | State contends multiple grounds supported revocation; any one suffices. | Williams challenges the basis but did not challenge all independent grounds. | Affirmed the revocation as to case 08-1708 for failure to challenge alternative grounds. |
Key Cases Cited
- Mendez v. State, 2011 Ark. 536 (Ark. 2011) (evidentiary abuse-of-discretion standard; prejudice required for reversal)
- Hanlin v. State, 356 Ark. 516 (Ark. 2004) (standard for abuse of discretion; relevance to door-opening)
- Wilburn v. State, 289 Ark. 224 (Ark. 1986) (invitation to discuss subject opens door for opposing party)
- Pursley v. Price, 283 Ark. 33 (Ark. 1984) (recognizes door-opening principle in evidentiary rulings)
- Barrett v. State, 354 Ark. 187 (Ark. 2003) (harmless-error consideration when guilt is overwhelming)
- Doyle v. State, 2009 Ark. App. 94 (Ark. App. 2009) (preponderance standard in probation revocation; multiple grounds)
- Breeden v. State, 2013 Ark. App. 522 (Ark. App. 2013) (affirmation on alternate grounds in revocation cases)
- Bedford v. State, 2014 Ark. App. 239 (Ark. App. 2014) (jurisdictional note on probation revocation timing)