Woods v. State, 567 S.W.3d 494

In March 2014 Woods forcibly removed Samantha Poole from a Monticello store, forced her into a car at gunpoint, and later shot and killed her; a deputy returned fire and Woods survived.
Woods was convicted of kidnapping (40 years) and capital murder (life without parole) and filed a timely Rule 37 petition alleging ineffective assistance of counsel (trial and appellate).
Two complaints at issue: (1) trial counsel referenced the O.J. Simpson case during voir dire and follow-up when a venireperson mentioned it, and (2) appellate counsel did not raise a sufficiency-of-the-evidence challenge on direct appeal.
The circuit court denied the Rule 37 petition without an evidentiary hearing, finding the record conclusively showed Woods was not entitled to relief.
Woods appealed; the Arkansas Supreme Court reviewed for clear error and applied the Strickland standard for ineffective-assistance claims.

Issue	Plaintiff's Argument (Woods)	Defendant's Argument (State)	Held
Whether trial counsel was ineffective for comparing the case to O.J. Simpson during voir dire	Counsel’s references to Simpson inflamed an all-white venire and prejudiced Woods; counsel’s follow-up was improper and merits an evidentiary hearing	The Simpson mention was responsive to a venireperson and fell within reasonable trial strategy; no prejudice shown	Court: No ineffective assistance; references were within wide range of reasonable professional assistance; denial without hearing affirmed
Whether appellate counsel was ineffective for not raising a sufficiency-of-the-evidence challenge on direct appeal	Appellate counsel failed to raise a meritorious insufficiency challenge to the kidnapping (and thus capital murder) conviction	Woods failed to identify specific preserved meritorious issues or facts that would have succeeded; substantial evidence supports convictions	Court: No relief. Woods did not show appellate counsel omitted a meritorious, preserved claim; evidence was sufficient; denial affirmed

Strickland v. Washington, 466 U.S. 668 (1984) (two-part ineffective-assistance test: deficient performance and prejudice)
Batson v. Kentucky, 476 U.S. 79 (1986) (prohibition on race-based peremptory strikes)
Penson v. Ohio, 488 U.S. 75 (1988) (standards on appellate counsel effectiveness and preservation)