David King v. State of Arkansas

2020 Ark. App. 532, 614 S.W.3d 823
CourtCourt of Appeals of Arkansas
DecidedNovember 18, 2020
StatusPublished
Cited by1 cases

This text of 2020 Ark. App. 532 (David King 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
David King v. State of Arkansas, 2020 Ark. App. 532, 614 S.W.3d 823 (Ark. Ct. App. 2020).

Opinion

Cite as 2020 Ark. App. 532

Reason: I attest to the accuracy ARKANSAS COURT OF APPEALS and integrity of this document Date: 2021-07-20 10:44:02 DIVISION IV Foxit PhantomPDF Version: 9.7.5 No. CR-20-125

Opinion Delivered: November 18, 2020

DAVID KING APPELLANT APPEAL FROM THE VAN BUREN COUNTY CIRCUIT COURT V. [NO. 71CR-16-48]

STATE OF ARKANSAS HONORABLE H.G. FOSTER, JUDGE APPELLEE AFFIRMED

MIKE MURPHY, Judge

Appellant David King was convicted by a Van Buren County jury of possession of

methamphetamine with purpose to deliver, simultaneous possession of drugs and firearms,

and possession of drug paraphernalia. The jury sentenced him to an aggregate term of

twenty-eight years’ imprisonment. On appeal, King argues that the trial court erred by (1)

refusing to order the State provide a video recording of the search of King’s home; (2) ruling

that the filmmakers were not state actors; (3) denying King’s request for a continuance to

obtain the video; (4) denying King’s motion to suppress evidence stemming from the

execution of the search warrant; and (5) declining to give the affirmative-defense instruction

to the jury. We affirm.

In March 2016, the Twentieth Judicial Drug Task Force along with several other

law enforcement officers executed a warrant for the search of King’s home. An HBO film

crew was also present at the search collecting footage for the documentary Meth Storm. Upon making entry into the house, King advised officers of a camouflage box located in his

bedroom that he knew contained methamphetamine. As an officer bent down to retrieve

the box, he located a handgun lying next to the box. Officers found over three grams of

methamphetamine in the camouflage box along with a pay/owe book, a digital scale, half a

straw with residue, a spoon, and multiple Ziplock bags. Officers located two more firearms

in the master bedroom and other drug paraphernalia throughout the house. During the

search, King made clear that his wife, Betty King, who was also present, knew nothing of

the items being found.

King was charged as a habitual offender with the crimes of possession of

methamphetamine or cocaine with purpose to deliver, simultaneous possession of drugs and

firearms, and possession of drug paraphernalia. King claimed that the officers violated the

terms and conditions of the search warrant by forcibly entering his home before the allotted

time frame. To prove this claim, King filed a motion to compel discovery of the video

recording filmed by the documentarians, but the court denied the motion finding that

because the State was not in possession of the recording, it was not required to turn it over.

After obtaining new counsel, King filed a motion to suppress the evidence procured during

the search arguing that the search warrant in the case specified that the search was to be

conducted between the hours of 6:00 a.m. and 8:00 p.m. and that despite the return of the

warrant indicating that the search began at 6:03 a.m., King maintained that officers began

the search several minutes before 6:00 a.m.

At the hearing on the motion, Agent Macy Brown, the lead agent who executed the

search, testified that it began at 6:03 a.m. based on the time he saw on the dashcam clock in

2 his vehicle when he pulled into the driveway. King and his wife testified that officers were

inside the home when Agent Brown told everyone to stop what they were doing because

they were early. Neither King nor his wife could provide a time when officers arrived or

when Agent Brown made everyone stop. King maintained that the video recording would

reveal the true time. At the conclusion of the hearing, the court denied the motion, again

rejecting that the State had any responsibility for HBO’s compliance with King’s request for

the recording, and it found that Agent Brown’s testimony that the warrant was executed in

a timely fashion was more credible than that put on by the defense. Upon the court’s ruling,

King moved for a continuance of the jury trial so that he may have another shot at trying

to retrieve the footage from HBO. The court stated that the case had been going on since

2016 and asked him what had previously been done to retrieve the footage, but King was

unsure. The court then denied the request.

A jury trial was conducted September 17, 2019. Charles Shaw, an investigator who

was present during the execution of the search warrant, testified that he was the one who

located the camouflage box and the gun in the bedroom, but he did not recall King’s wife

being present during the search. Agent Brown then testified about what was found during

the search and that King’s wife was, in fact, present. He also testified that after the search,

he detained King, King waived his Miranda rights, and Agent Brown conducted an

interview. He testified that during the interview, King admitted that he had just bought a

thousand dollars’ worth of methamphetamine the day before and that he used between half

and a quarter each day. Agent Brown testified that he did not find a thousand dollars’ worth

of methamphetamine in the house and that in his experience, King’s admitted use was a

3 typical answer of a regular user. King moved for directed verdict at the close of the State’s

case in chief, arguing that the State failed to meet the elements of the simultaneous-

possession-of-drugs-and-firearms charge. The trial court denied the motion. The defense

rested without calling any witness and renewed its motion, which the court again denied.

Prior to jury deliberation, King sought to have a jury instruction for the affirmative defense

for the charge of simultaneous possession of drugs and firearms, arguing that the firearm was

not readily available for use. Finding that there was no factual basis from which the jury

could find that the firearm was not available for use because the gun was in close proximity

with the drugs and paraphernalia in the bedroom, the court denied King’s request. King

was convicted and has now timely appealed.

Questions of law, such as the interpretation of discovery rules found in the Arkansas

Rules of Criminal Procedure, are reviewed de novo. Muhammad v. State, 67 Ark. App. 262,

265, 998 S.W.2d 763, 763 (1999). However, when we review a court’s rulings regarding

alleged violations of the rules of discovery, the standard of review is abuse of discretion.

Hicks v. State, 340 Ark. 605, 612, 12 S.W.3d 219, 223 (2000).

On appeal, King first argues that the trial court erred in ruling that the State was not

responsible for providing him with the HBO video footage. King maintains that the video

could lead to exculpatory evidence to support his motion to suppress that the officers

executed the warrant outside the proper timeframe. King asserts that it was an abuse of

discretion for the trial court to find that because the State did not possess the video that it

did not have to provide the video. King asserts that, at a minimum, the trial court should

have ordered the State to make diligent efforts to obtain the footage or information relating

4 to the individuals who recorded the video. To support his argument, King states that the

court made its finding in violation of Arkansas Rules of Criminal Procedure 17.1, 17.3, and

17.4; Barrow v.

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2021 Ark. App. 132 (Court of Appeals of Arkansas, 2021)

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