Christopher Rice v. State of Arkansas

2022 Ark. App. 32
CourtCourt of Appeals of Arkansas
DecidedJanuary 26, 2022
StatusPublished

This text of 2022 Ark. App. 32 (Christopher Rice 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
Christopher Rice v. State of Arkansas, 2022 Ark. App. 32 (Ark. Ct. App. 2022).

Opinion

Cite as 2022 Ark. App. 32 Elizabeth Perry I attest to the accuracy and ARKANSAS COURT OF APPEALS integrity of this document DIVISION II 2023.08.15 12:02:31 -05'00' No. CR-21-361

2023.003.20269 Opinion Delivered January 26, 2022 CHRISTOPHER RICE APPELLANT APPEAL FROM THE ASHLEY V. COUNTY CIRCUIT COURT [NO. 02CR-18-133] STATE OF ARKANSAS APPELLEE HONORABLE ROBERT B. GIBSON III, JUDGE

AFFIRMED

RITA W. GRUBER, Judge

Appellant Christopher Rice brings this appeal from the revocation of his probation.

His sole point on appeal is that the circuit court failed to make an appropriate inquiry into

his financial ability to afford counsel. We hold that the circuit court did not abuse its

discretion and affirm Rice’s revocation.

On May 7, 2019, Rice pleaded guilty to failure to register as a sex offender. He was

sentenced to sixty months’ probation and ordered to pay $285 in fees and costs. On

November 18, 2020, probation officers checked on Rice at his home and discovered pistols,

shotguns, and a meth pipe. He was arrested and charged with being a felon in possession of

a firearm and with being in possession of drug paraphernalia. On December 30, 2020, the

State also filed a petition to revoke his probation based on the new charges.

The court held a preliminary hearing on January 11, 2021, during which it asked

Rice whether he had an attorney, to which he replied he did not. The court then asked whether he could afford an attorney, and Rice replied that he could, that he had just gone

back to work, and that he planned to hire one. The court stated, “If you tell me you can

afford an attorney, I’ll give you the opportunity to get one,” and it set a hearing for February

16, telling Rice he “better have a lawyer” by then. Rice replied, “I’ll have somebody by

then.”

The hearing was rescheduled for March 1, Rice failed to appear, and the court issued

a warrant. When Rice appeared later that afternoon, several witnesses were unable to return

to conduct the hearing that day. But the court asked Rice whether he had hired an attorney,

and Rice replied that he had not but planned to do so that week. Rice did not indicate that

he was indigent, nor did he ask the court to appoint a lawyer for him. The court then asked

Rice how much money he earns, and Rice said he makes “around a thousand a week.”

The following discussion took place.

COURT: I certainly can’t find you indigent making fifty-something-thousand dollars a year. And so you’ve had more than sufficient time to hire a lawyer at $1,000 a week. Mrs. Callahan, when did we have his preliminary?

ASSISTANT: January the 11th, I believe.

COURT: January the 11th. And your case has been pending since before that. And so that’s —

RICE: Well, I was laid off work, Your Honor, before. And I went back to work the week of. When I came back to court that week, that was my first week back to work.

COURT: So seven or eight weeks, or longer, at $1,000 a week, and so — You know, you’re welcome to hire one, but you’ve got two proceedings and one of them is going to move forward tomorrow; and that’s your revocation hearing, unless there’s some objection by the State —

[No objection]

2 COURT: So tomorrow we’re going to have your revocation hearing. Obviously, if you want to hire a lawyer, you can hire a lawyer.

The court then placed Rice in the Ashley County Detention Facility on the failure-to-

appear warrant, told him he was entitled to a phone call, and advised that he might want to

alert his family of the situation.

At the hearing the next day, the court asked Rice if he was still “unrepresented,” and

Rice said, “[S]ince you made me stay the night here last night I ain’t got no lawyer.” The

court noted that Rice earns $1,000 a week, that it could not find him indigent, that he had

two months to hire an attorney, and that he had informed the court in January that he

would hire an attorney for the then scheduled February hearing. Rice explained he had

been “catching up” on his bills, and he was going to get an attorney “this week.” The court

said that Rice had plenty of time to make arrangements and that he was entitled to make

phone calls from the Ashley County Detention Facility just as he could have from anywhere

else.

The court then continued with the probation-revocation hearing. Testimony at the

hearing indicated that a meth pipe and numerous firearms had been discovered during a

routine check of Rice’s home. Rice testified that he was unaware of the existence of the

firearms on the property, but he admitted that he did have a meth pipe and that he had been

using drugs. There was also testimony introduced that Rice owed $210 on his costs, fines,

and fees and that he had tested positive for amphetamines on February 11. Because Rice

does not challenge the sufficiency of the evidence, we need not detail the testimony here.

The court found that Rice had violated the terms of his probation, specifically, for possessing

3 firearms, for committing an offense punishable by jail or prison, and for possessing or

consuming a controlled substance.

Rice’s sole argument on appeal is that the circuit court erred in failing to make an

appropriate inquiry into his financial ability to afford counsel, so we turn to the law

governing a defendant’s right to counsel. The Sixth Amendment to the United States

Constitution, made obligatory on the states by the Due Process Clause of the Fourteenth

Amendment, guarantees an accused the right to have the assistance of counsel for his defense.

Gideon v. Wainwright, 372 U.S. 335, 342–44 (1963). Article 2, section 10 of the Arkansas

Constitution provides that an accused in a criminal prosecution has the right to be heard by

himself and his counsel. A criminal defendant has a right to represent himself at trial when

his waiver of the right to counsel is knowingly and intelligently made. Faretta v. California,

422 U.S. 806 (1975). Finally, Arkansas Rule of Criminal Procedure 8.2(a) (2020) provides

that a judicial officer shall determine “whether the defendant is indigent and, if so, appoint

counsel to represent him” at the first appearance unless the defendant knowingly and

intelligently waives the appointment of counsel. Patton v. State, 2019 Ark. App. 63, at 6,

569 S.W.3d 906, 909 (emphasis added).

In the instant case, the circuit court found that appellant was not indigent. Indeed,

Rice never argued that he was indigent. On appeal, the standard of review is whether the

circuit court abused its discretion in finding that petitioner was not indigent. Hill v. State,

304 Ark. 348, 350, 802 S.W.2d 144, 145 (1991). The criteria to be used in determining the

indigency of a defendant are set out in Burmingham v. State, 342 Ark. 95, 101, 27 S.W.3d

351, 355 (2000). Indigency is considered on a case-by-case basis, and the burden of

4 establishing one’s status as a pauper is on the defendant claiming indigent status. Id. Although

there is no set test for indigency, which is a mixed question of fact and law, some of the

factors to be considered are (1) income from employment and governmental programs such

as Social Security and unemployment benefits; (2) money on deposit; (3) ownership of real

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Related

Faretta v. California
422 U.S. 806 (Supreme Court, 1975)
Burmingham v. State
27 S.W.3d 351 (Supreme Court of Arkansas, 2000)
Patton v. State
2019 Ark. App. 63 (Court of Appeals of Arkansas, 2019)
Kincade v. State
796 S.W.2d 580 (Supreme Court of Arkansas, 1990)
Hill v. State
802 S.W.2d 144 (Supreme Court of Arkansas, 1991)
Gideon v. Wainwright
372 U.S. 335 (Supreme Court, 1963)

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2022 Ark. App. 32, Counsel Stack Legal Research, https://law.counselstack.com/opinion/christopher-rice-v-state-of-arkansas-arkctapp-2022.