Anthony Baumann v. State of Arkansas

2021 Ark. App. 58
CourtCourt of Appeals of Arkansas
DecidedFebruary 10, 2021
StatusPublished
Cited by2 cases

This text of 2021 Ark. App. 58 (Anthony Baumann v. State of Arkansas) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anthony Baumann v. State of Arkansas, 2021 Ark. App. 58 (Ark. Ct. App. 2021).

Opinion

Cite as 2021 Ark. App. 58 Elizabeth Perry ARKANSAS COURT OF APPEALS I attest to the accuracy and DIVISION II integrity of this document No. CR-20-415 2023.06.22 12:47:48 -05'00' 2023.001.20174 OPINION DELIVERED: FEBRUARY 10, 2021

ANTHONY BAUMANN APPELLANT APPEAL FROM THE BENTON COUNTY CIRCUIT COURT [NO. 04CR-15-154] V. HONORABLE ROBIN F. GREEN, JUDGE STATE OF ARKANSAS APPELLEE AFFIRMED

ROBERT J. GLADWIN, Judge

Appellant Anthony Baumann appeals the Benton County Circuit Court’s order

denying his petition for postconviction relief pursuant to Rule 37.1 of the Arkansas Rules

of Criminal Procedure (2020). Baumann argues in two points on appeal that his trial counsel

was ineffective and that the circuit court erred in its rulings. We affirm the circuit court’s

denial of Baumann’s petition for postconviction relief.

I. Procedural History

On May 21, 2015 a felony information was filed charging Baumann with one count

of sexual assault in the second degree in Benton County Circuit Court based on an allegation

that he assaulted his granddaughter’s half sister, E.S. An amended felony information was

filed on September 21, 2016, charging him with one count of sexual assault in the second

degree and one count of rape. At a hearing held on November 2, 2016, regarding the testimony of Baumann’s

daughter, Tanya Bridges (Tanya), the circuit court denied Baumann’s motion to exclude

the testimony pursuant to Arkansas Rule of Evidence 404(b). On June 6, 2017, Baumann

moved to suppress certain testimony after the State sought to admit additional Rule 404(b)

witnesses, and the circuit court determined that the additional Rule 404(b) evidence was

inadmissible.

Baumann’s jury trial was held on September 26–29, 2017, during which he

successfully moved for a partial directed verdict and was acquitted on the rape charge.

However, the jury found Baumann guilty of sexual assault in the second degree and

sentenced him to twenty years in the Arkansas Department of Correction pursuant to a

sentencing order entered on October 17. A notice of appeal was timely filed on October

12.

Baumann argued that (1) the circuit court erred by permitting Tanya to testify about

similar acts of sexual assault pursuant to Rule 404(b); (2) the circuit court erred by refusing

to exclude Tanya’s testimony pursuant to Ark. R. Evid. 403; and (3) the State’s questioning

of detective Brian Hanna regarding other sexual-assault accusations against Baumann

warranted a mistrial. This court affirmed on November 28, 2018, holding that the circuit

court did not abuse its discretion by admitting Tanya’s testimony pursuant to the “pedophile

exception” to Rule 404(b). Baumann v. State, 2018 Ark. App. 564, at 13, 566 S.W.3d 494,

502. This court declined to consider Baumann’s remaining arguments, holding that he did

not obtain a clear ruling on his Rule 403 argument and did not move for a mistrial after

2 objecting to Detective Hanna’s testimony. Id. at 14–18, 566 S.W.3d at 503–05. Our

supreme court denied his petition for review, and the mandate issued on January 17, 2019.

Baumann filed a timely petition for relief under Rule 37 on March 13, 2019, with

the Benton County Circuit Court, with assistance of counsel, which alleged errors by trial

counsel and contained a proper verification. In his petition, he alleged the following:

1. Trial counsel was ineffective in failing to request a mistrial after the State asked a detective to read a portion of the alleged victim’s Children’s Safety Center (CSC) interview, which had been excluded as Rule 404(b) evidence in the form of hearsay.

2. Trial counsel was ineffective in failing to establish for the jury a theory of the case for why the alleged victim, who was a minor, and other State’s witnesses would have a motive to make false accusations that Baumann committed sexual assault and rape.

After two extensions, the State filed a response and brief in support on June 13, 2019.

The circuit court did not hold a hearing on the matter but instead, following the parties’

submissions, entered a five-page written order that denied relief on March 4, 2020.

In its order, the circuit court denied relief on Baumann’s first claim, that trial counsel

was ineffective for failing to request a mistrial, finding that trial counsel was not ineffective in

choosing not to move for a mistrial, because Baumann had not demonstrated that this

decision fell below an objective standard of reasonableness. The circuit court, citing

McClinton v. State, 2015 Ark. 245, 464 S.W.3d 913, noted that a mistrial is a drastic remedy

available only when an error has occurred that is so prejudicial as to be beyond repair and

to affect the fundamental fairness of a trial. The circuit court acknowledged Baumann’s

taking issue with certain testimony elicited by the State during a direct examination of

Detective Hanna when he was asked to quote from a transcript of a CSC interview of the

alleged victim, E.S. The quote was truncated by an objection from trial counsel, and the

3 proceedings moved on. The circuit court determined that this testimony, similar to the cases

of Brown v. State, 2019 Ark. App. 36, 568 S.W.3d 312; and Marbley v. State, CR 07-06,

2007 WL 2660224, at *2–3 (Ark. App. Sept. 12, 2007) (unpublished), cited by the State,

lacked any sort of context that would have made it so prejudicial to a jury as to merit a

mistrial. To the extent the quote contained prejudicial information in referencing other

alleged victims, the circuit court pointed out that the quote itself named “Tanya,” another

witness in the case, and not Baumann.

Further, the circuit court noted that other alleged victims referenced in the quote

were made known to the jury at a later point in the trial and that trial counsel had referred

to their allegations as false. The circuit court also stated that Baumann himself advocated for

this trial strategy on Issue 2 of his Rule 37 petition. The circuit court found that, had it been

made, a motion for mistrial would not have been granted, and absent a demonstration that

such a motion would have been granted, there is no showing of prejudice. See England v.

State, 2018 Ark. App. 137, at 4, 543 S.W.3d 553, 559. The circuit court further indicated

that Baumann was acquitted of the rape charge on trial counsel’s directed-verdict motion

subsequent to the decision not to request a mistrial. The circuit court found, accordingly,

that it was apparent that the decision not to request a mistrial was a fruitful trial strategy.

The decision to not request a mistrial falls within trial strategy if supported by reasonable

professional judgment. Sims v. State, 2015 Ark. 363, 472 S.W.3d 107; Camargo v. State, 346

Ark. 118, 55 S.W.3d 255 (2001).

Next, the circuit court rejected Baumann’s second claim, that his trial counsel was

ineffective for failing to establish for the jury a theory of the case for why the alleged victim, who was a

4 minor, and other State’s witnesses would have a motive to make false accusations that Baumann

committed sexual assault and rape. The circuit court found that trial counsel was not ineffective

when it did not specifically adopt the alternate theories proposed by Baumann, noting that

the decision of which theory to pursue as a defense falls within the protections of trial

strategy. Flowers v. State, 2010 Ark.

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