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Snell v. State

Citations: 287 Ark. 264; 698 S.W.2d 289; 1985 Ark. LEXIS 2226Docket: CR 85-109

Court: Supreme Court of Arkansas; November 4, 1985; Arkansas; State Supreme Court

Narrative Opinion Summary

In this case, the appellant was convicted of murdering a state trooper and sentenced to life imprisonment without the possibility of parole. On appeal, he raised three primary issues. First, he challenged the constitutionality of a death qualified jury, claiming it violated his right to a fair trial; however, the court maintained its position from previous decisions, thereby rejecting this claim. Second, he objected to the court’s denial of a challenge for cause against a juror who had expressed a preformed opinion of his guilt. Although the court voiced doubts about the juror's rehabilitation, it found no error since the juror was removed via a peremptory challenge, and no biased jurors were shown to have participated in the trial. Third, the appellant contested the admission of evidence regarding weapons unrelated to the murder weapon, arguing their prejudicial effect outweighed their probative value. The court, however, held that the evidence was relevant to establishing premeditation and did not find any prejudicial error. Ultimately, the court affirmed the conviction, with one justice not participating in the decision.

Legal Issues Addressed

Admissibility of Evidence under Unif. R. of Evid. 403

Application: The court addressed the admissibility of weapons found in the appellant's possession, determining that their probative value was not outweighed by potential prejudice, supporting the prosecution's theory of premeditation.

Reasoning: The appellant argues that the prosecution sought to introduce evidence of other weapons solely to portray the appellant negatively and bias the jury, referencing Unif. R. of Evid. 403, which allows for the exclusion of relevant evidence if its prejudicial effect outweighs its probative value.

Challenge for Cause Against Juror

Application: The appellant contested the denial of a challenge for cause against a juror with a preformed opinion of guilt. The court found no error as the juror was excused via peremptory challenge, and no biased juror participated in the trial.

Reasoning: On the juror issue, a prospective juror who expressed a preformed opinion of Snell's guilt was ultimately not excused for cause after stating she could follow the judge’s instructions. The defense later used a peremptory challenge to excuse her.

Constitutionality of Death Qualified Jury

Application: The appellant challenged the constitutionality of a death qualified jury, arguing it violated his right to a fair trial. The court upheld its precedent and found no reversible error.

Reasoning: Regarding the death qualified jury, Snell argued that dismissing jurors opposed to the death penalty violated his right to a fair trial, referencing Grigsby v. Mabry. However, the court declined to reconsider its previous rulings rejecting that claim, including decisions in Hall v. State and Rector v. State.