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Walton v. State
Citations: 232 Ark. 86; 334 S.W.2d 657; 1960 Ark. LEXIS 361Docket: 4969
Court: Supreme Court of Arkansas; April 18, 1960; Arkansas; State Supreme Court
Jim Johnson, Associate Justice, addressed the appeal of Edward Walton, Jr., who was charged with first-degree murder and entered a guilty plea. A jury was convened to determine the appropriate punishment, as the law mandates a jury's involvement in cases of confession. The court instructed the jury that Walton's guilty plea eliminated the presumption of innocence, limiting their deliberation solely to sentencing options: death by electric chair or life imprisonment. After deliberation, the jury found Walton guilty and sentenced him to death. Walton, a Black man convicted of murdering a 61-year-old white man, argued that the death sentence was excessively harsh and sought commutation to life imprisonment. His counsel claimed a fair trial was provided and requested the court to consider mitigating factors. Upon reviewing the case, the court concluded that the evidence supported the jury's decision and found no merit in Walton's arguments for reversal. The appellant had only raised two objections during the trial. The court found that the first allegation of error was upheld, while the second was without merit. There was no motion for a new trial. The verdict and judgment would typically be affirmed, but the court must examine the record for any apparent errors. Under Arkansas statute 43-2152, established shortly after statehood in 1838, juries must determine whether a murder conviction is for first or second degree. If a defendant confesses, a jury still must assess the degree of the crime. In this case, the jury was improperly instructed, limiting them to finding the appellant guilty of first degree murder without the opportunity to determine the degree. The court's instructions effectively removed the jury's discretion, only allowing them to decide between death or life imprisonment. Previous cases, such as Porter v. State and Lancaster v. State, upheld that the statute mandates a specific finding of the murder degree, even with a confession. The court noted a significant distinction between the verdict in this case and in Wells v. State, where an error in jury instruction led to a reversal due to defects in the verdict. Despite the appellant’s acknowledgment of a fair trial, the court stated that errors in instructions warranted a reversal and remanding for a new trial, asserting that the mandatory nature of the statute must be enforced.