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Ingram v. State
Citations: 255 Ark. 6; 498 S.W.2d 862; 1973 Ark. LEXIS 1299Docket: CR 73-39
Court: Supreme Court of Arkansas; September 4, 1973; Arkansas; State Supreme Court
Daniel Ingram, Jr., Raymond Pruitt, and Willie Stovall were jointly convicted of raping Mrs. McCulley and sentenced to thirty years in prison. Their appeal included four arguments for reversal, all deemed without merit. On July 18, 1972, the McCulleys, hitchhiking in Pulaski County, were picked up by the appellants, who instead of taking them to Memphis, drove to a secluded area where they locked Mr. McCulley in the trunk and raped Mrs. McCulley. After the assault, the appellants stole Mr. McCulley’s watch and fled. The couple reported the incident to the police, leading to the arrest of the appellants based on their vehicle description. Each appellant confessed to the crime, with the trial judge confirming the confessions were voluntary after a Denno hearing. The McCulleys identified the appellants and linked them to the crime through a book of matches found in their car, which advertised the McCulleys' Florida bank. The appellants argued against the admission of testimony regarding the robbery of the watch, claiming it was irrelevant to the rape charge. However, the court found the robbery evidence pertinent as it helped establish the appellants as the assailants. The second and third arguments pertained to the prosecuting attorney's use of Ingram’s original confession during cross-examination, despite previous edits that omitted references to the other defendants. The trial court allowed this, instructing the jury to consider it only regarding Ingram's credibility and not as evidence against the others. The court affirmed that the objection to the confessions was resolved once all defendants testified and underwent cross-examination, referencing precedents where similar issues had been addressed. The appellants' claim of error was rejected, as their distinctions from prior cases were not compelling. Each appellant claimed under oath that the McCulleys and police officers provided false testimony. The court found this testimony neither unfavorable to the codefendants nor limiting their right to cross-examination. The appellants argued that the prosecuting attorney improperly used Ingram’s original confession for impeachment since it was not previously introduced in evidence. The court clarified that the confession became admissible when Ingram testified, and no request was made by the defendants to introduce it formally. The absence of such a request or evidence of prejudice to the defendants negated their argument. Additionally, the appellants contended that the trial court should have granted separate trials. The decision to grant severance in non-capital cases is at the trial court's discretion. Since all three appellants denied involvement and asserted alibis with no essential conflict in their defenses, the court found no abuse of discretion in requiring a joint trial. The ruling was affirmed.