Elizabeth Haynie v. State of Arkansas

2025 Ark. 46, 709 S.W.3d 46
CourtSupreme Court of Arkansas
DecidedApril 24, 2025
StatusPublished
Cited by4 cases

This text of 2025 Ark. 46 (Elizabeth Haynie v. State of Arkansas) is published on Counsel Stack Legal Research, covering Supreme Court of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Elizabeth Haynie v. State of Arkansas, 2025 Ark. 46, 709 S.W.3d 46 (Ark. 2025).

Opinion

Cite as 2025 Ark. 46 SUPREME COURT OF ARKANSAS No. CR-24-157

Opinion Delivered: April 24, 2025 ELIZABETH HAYNIE APPELLANT APPEAL FROM THE OUACHITA COUNTY CIRCUIT COURT V. [NO. 52CR-21-272]

STATE OF ARKANSAS HONORABLE EDWIN KEATON, APPELLEE JUDGE

AFFIRMED.

BARBARA W. WEBB, Justice

Appellant Elizabeth Haynie shot and killed her husband, Jerome Haynie. She was

convicted of first-degree murder and sentenced to life imprisonment plus an additional

fifteen years for a firearm enhancement. On appeal, Haynie argues (1) that the State failed

to present sufficient evidence to negate her justification defense and (2) that the circuit court

erred by admitting two photographs taken at the murder scene. We affirm.

I. Background

On September 6, 2021, Ouachita County Sheriff Deputy Derrick Aplin responded

to a call at a house on Highway 24. At the house, Deputy Aplin first encountered a male

child in the carport who informed him that his father had been shot. He then encountered

a hysterical Haynie who stated that her husband needed an ambulance. Deputy Aplin found

Jerome lying dead on the floor in the back bedroom. A Glock handgun was lying near the

body. When asked what happened, Haynie said, “We were arguing. We keep a gun there on the gun cabinet. And he was pushing me. We were arguing. And I grabbed it and he

pushed me and it went off.”

Dr. Jennifer Forsyth, a forensic pathologist with the Arkansas State Crime

Laboratory, performed the autopsy on Jerome. She concluded the cause of death to be

gunshot wounds to the head and the chest. Zachary Elder, a firearm and toolmark examiner

with the state crime lab examined the Glock handgun, bullets, and shell casings found at the

crime scene. He concluded that the shell casings had been fired from the Glock.

At trial, Haynie pursued a justification defense. She adduced evidence that she

suffered physical abuse from Jerome throughout their marriage. Haynie explained that on

the night of the murder, she and Jerome began fighting after she refused to perform a sexual

act. According to Haynie, Jerome hit her in the face and started choking her. He then

threatened to kill Haynie and their children. She added that she grabbed a handgun before

Jerome could get it, the two fought, and then the gun went off twice.

Through the testimony of Captain David Pennington, the State moved to introduce

two photographs of a suitcase located in the closet where one of the shell casings was found.

Haynie objected to the introduction of these photographs, arguing that they were irrelevant

and potentially misleading. The State responded, asserting that the photographs were

relevant to Haynie’s motive. The prosecuting attorney explained that evidence of the packed

suitcase indicated Jerome was planning to leave Haynie. The circuit court admitted the

photographs over Haynie’s objection.

Haynie moved for a directed verdict at the close of the State’s case. She argued that

the State failed to present sufficient evidence that she purposely killed Jerome. The State

2 noted that two separate shots had been fired, indicating the shooting was not an accident.

The circuit court denied the motion. After the defense rested, Haynie renewed her directed-

verdict motion on the same grounds. The motion was again denied.

Haynie was subsequently convicted of first-degree murder and sentenced to life

imprisonment plus fifteen years with the firearm enhancement. Haynie appeals. She argues

(1) that the State failed to negate her justification defense and (2) that the circuit court erred

by admitting the suitcase photographs.

II. Discussion

A. Sufficiency of the Evidence

For her first point, Haynie argues that insufficient evidence supports her first-degree-

murder conviction because the State failed to negate her justification defense. However, this

argument is unpreserved for our review.

Arkansas Rule of Criminal Procedure 33.1(a) provides that “[i]n a jury trial, if a

motion for directed verdict is to be made, it shall be made at the close of the evidence

offered by the prosecution and at the close of all of the evidence.” A directed-verdict motion

“shall state the specific grounds therefor.” Ark. R. Crim. P. 33.1(a). A defendant is bound

by the scope and nature of his directed-verdict motion at trial and cannot change the ground

on appeal. White v. State, 2023 Ark. 90, 667 S.W.3d 533. Specifically, we have held that an

argument that the State failed to negate self-defense was unpreserved when the appellant

made only a general motion to the circuit court and did not specify how the State’s proof

was insufficient to meet its burden. Kinsey v. State, 2016 Ark. 393, at 9, 503 S.W.3d 772,

778.

3 Here, Haynie did not make even a general motion that the State failed to negate self-

defense. Rather, Haynie argued in her motion that the State did not prove she purposely

killed Jerome, contending, “There hasn’t been any evidence or testimony as to purpose.”

Haynie was confined to this argument on appeal, which she declined to raise. As such, her

argument regarding justification is unpreserved for our review. See Bridges v. State, 2023

Ark. 157, at 4, 676 S.W.3d 275, 278 (declining to address a justification argument that was

not raised in a directed-verdict motion).

B. Admission of Photographs

Haynie next argues that the circuit court erred by admitting photographs of a suitcase

in the closet where one of the shell casings was found. She contends that the photographs

are irrelevant and misleading.

The admission of photographs is a matter left to the circuit court’s sound discretion,

and we will not reverse absent an abuse of that discretion. Collins v. State, 2020 Ark. 371,

610 S.W.3d 653. Evidence is relevant if it has the “tendency to make the existence of any

fact that is of consequence to the determination of the action more probable or less probable

than it would be without the evidence.” Ark. R. Evid. 401. Photographs may be admissible

if they assist the trier of fact by shedding light on some issue, or by proving a necessary

element of the case. See Smith v. State, 2024 Ark. 161, 699 S.W.3d 92.

The State sought to introduce the photographs as evidence of state of mind and

intent. In particular, the State asserted that the packed suitcase indicated Jerome was planning

to leave and that Haynie shot and killed him in response. This evidence goes to the State’s

burden of proving a necessary element of first-degree murder––purpose. Ark. Code Ann. §

4 5-10-102(a)(2) (Repl. 2024). Accordingly, the circuit court did not abuse its discretion by

admitting the photographs.

III. Rule 4-3(a) Review

In compliance with Arkansas Supreme Court Rule 4-3(a), the record has been

examined for all objections, motions, and requests made by either party that were decided

adversely to Haynie. No prejudicial error has been found.

Special Justice BILENDA HARRIS-RITTER joins.

WOOD, J., concurs.

BRONNI, J., not participating.

RHONDA K. WOOD, Justice, concurring. I join the majority’s disposition but

would affirm the admission of the photographs for a different reason. At trial, Haynie

objected to photographs of the victim’s closet and a suitcase in that closet based on

Free access — add to your briefcase to read the full text and ask questions with AI

Related

KEENAN HUDSON v. STATE OF ARKANSAS
Supreme Court of Arkansas, 2025
CHRISTOPHER MCDANIELS v. STATE OF ARKANSAS
Supreme Court of Arkansas, 2025
TIMOTHY CLEVENGER v. STATE OF ARKANSAS
Supreme Court of Arkansas, 2025
Alan Strong v. State of Arkansas
2025 Ark. App. 352 (Court of Appeals of Arkansas, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ark. 46, 709 S.W.3d 46, Counsel Stack Legal Research, https://law.counselstack.com/opinion/elizabeth-haynie-v-state-of-arkansas-ark-2025.