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Addington v. State
Citations: 2 Ark. App. 7; 616 S.W.2d 742; 1981 Ark. App. LEXIS 717Docket: CA CR 81-36
Court: Court of Appeals of Arkansas; May 27, 1981; Arkansas; State Appellate Court
James R. Cooper, Judge, presided over the case where the appellant was convicted of theft of property and sentenced to 20 years in prison as a habitual offender. The appellant argued for reversal on two grounds: the trial court's refusal to suppress a statement made to Captain Gary Wilson, asserting that he did not knowingly and intelligently waive his right to counsel, and the court's denial of a requested jury instruction. The appellant was arrested on August 1, 1980, for possession of a stolen vehicle and later confessed to the crime on August 5, 1980, after being informed of his Miranda rights twice. Although the State did not use this confession during the guilt phase of the trial, it later presented Captain Wilson's testimony to establish the appellant's prior felony convictions. The statute governing the proof of prior convictions allows various forms of evidence to establish a defendant's criminal history. The appellant did not dispute the methods used to prove his prior convictions but contended that his confession was involuntary due to the circumstances surrounding his waiver of counsel. The law presumes that statements made in custody are involuntary, placing the burden on the State to demonstrate otherwise. The court must assess the voluntariness of confessions based on the totality of circumstances, resolving doubts in favor of individual rights. The appellant argued that Captain Wilson should have recognized the imminent judicial proceeding concerning appointed counsel and thus should not have taken the statement. Appellant contends that the police's knowledge and his own lack of understanding prevented him from knowingly and intelligently waiving his right to counsel during an interview with Captain Wilson. Although he acknowledges needing an attorney, he does not claim mistreatment or that his incarceration duration affected his statement's voluntariness. The trial court's finding of voluntariness is upheld, as it is not clearly against the evidence. Appellant cites Sutton v. State to support his argument, but that case differs as it involved an indigent defendant who made a statement without counsel after a preliminary hearing. However, the court finds grounds for reversal due to the improper admission of evidence regarding appellant's prior convictions, as the state did not demonstrate that he had counsel during those convictions. Previous cases establish that the state must prove either representation by counsel or a knowing waiver of that right before admitting such evidence. The only evidence presented by appellant indicates he had an attorney for one conviction, but the state failed to provide proof for the other six. Appellant's substantial rights were affected by the admission of this potentially unconstitutional evidence. The judgment is reversed and the case remanded for a new trial unless the prosecution can prove that appellant was represented by counsel in prior cases. The court addressed the appellant's claim that the trial court erred by not providing the requested instruction on the definition of "knowingly" as outlined in AMCI 4002. The appellant contended that this definition was essential to prove that he knowingly engaged in prohibited conduct. The instruction given by the trial court stated that the State must prove beyond a reasonable doubt that the defendant knowingly took property with the intent to deprive the owner, defining "knowingly" as being aware of his conduct's nature. The appellant did not argue that the given instruction was incorrect, but rather that the definitions of "knowingly" in AMCI 4002 and other model instructions differ, and that the requested instruction should have been included. The court noted that the trial court’s instruction sufficiently covered the subject matter, referencing previous cases that establish no error in refusing to give additional instructions if the law is already adequately addressed. It concluded that the requested instruction would have been redundant and potentially confusing for the jury. Consequently, the court found no error in the trial court's decision and reversed and remanded the case for a new trial.