James N. Bynum v. State of Arkansas

2021 Ark. App. 298, 626 S.W.3d 154
CourtCourt of Appeals of Arkansas
DecidedJune 2, 2021
StatusPublished
Cited by3 cases

This text of 2021 Ark. App. 298 (James N. Bynum 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
James N. Bynum v. State of Arkansas, 2021 Ark. App. 298, 626 S.W.3d 154 (Ark. Ct. App. 2021).

Opinion

Cite as 2021 Ark. App. 298 Elizabeth Perry ARKANSAS COURT OF APPEALS I attest to the accuracy and integrity of this document DIVISION III No. CR-20-444 2023.06.28 11:46:38 -05'00' 2023.001.20174 Opinion Delivered June 2, 2021

JAMES N. BYNUM APPEAL FROM THE SCOTT APPELLANT COUNTY CIRCUIT COURT [NO. 64CR-14-104] V. HONORABLE JERRY DON RAMEY, JUDGE STATE OF ARKANSAS APPELLEE AFFIRMED; REMANDED TO CORRECT SENTENCING ORDER

KENNETH S. HIXSON, Judge

Appellant James N. Bynum was convicted in a jury trial of one count of second-

degree sexual assault committed against T.H. and one count of second-degree sexual assault

committed against C.P. T.H. and C.P. were minors when the offenses were committed.

For these offenses, Bynum was sentenced to two concurrent five-year prison terms.

Bynum now appeals, raising four arguments for reversal. His first and third

arguments challenge the sufficiency of the evidence supporting his convictions. Bynum’s

remaining two arguments assign error with respect to the jury instructions and the

sentencing order entered by the trial court. We affirm.

This case has a long history and has been to our court twice before. In 2015, Bynum

was sentenced to 100 years in prison after a jury found him guilty of ten counts of fourth-

degree sexual assault committed against A.H. and one count each of second-degree sexual assault committed T.H. and C.P. On appeal, this court affirmed the second-degree sexual

assaults committed against T.H. and C.P., but we reversed and dismissed the ten convictions

for fourth-degree sexual assault committed against A.H. because all of these charges were

filed after the applicable statute of limitations had expired. See Bynum v. State, 2017 Ark.

App. 41, 511 S.W.3d 860 (Bynum I).

After our mandate in Bynum I was issued, Bynum timely filed a motion for

postconviction relief with the trial court pursuant to Arkansas Rule of Criminal Procedure

37.1. The trial court denied Bynum’s Rule 37 petition. However, we reversed the trial

court’s denial of postconviction relief holding that Bynum received ineffective assistance of

counsel because his trial counsel had failed to move to dismiss the charges relating to A.H.,

all of which were clearly barred by the statute of limitations. See Bynum v. State, 2018 Ark.

App. 477, 561 S.W.3d 755 (Bynum II). We held that charging Bynum for twelve offenses

instead of two was prejudicial to Bynum as was A.H.’s testimony about the ten time-barred

allegations. Id. Accordingly, we reversed and remanded for a new trial on the second-

degree sexual-assault charges concerning T.H. and C.P.

After being retried on November 1, 2019, the jury again convicted Bynum of one

count each of second-degree sexual assault committed against T.H. and C.P. From these

convictions, this third appeal (Bynum III) arises.

Because all the arguments raised in this appeal are related to the contents of the

amended information filed by the State on October 25, 2019, it is necessary to recite the

amended information in its entirety. The October 25, 2019, amended information states:

Comes the Prosecuting Attorney for the FIRST Division of SCOTT County, Arkansas, and in the name and by the authority of the State of Arkansas, charges

2 James N. Bynum with the crimes(s) of Sexual Assault, Second Degree (8/16/2013[1] and thereafter) as follows:

COUNT 1: Sexual Assault, Second Degree (8/16/2013 and thereafter) ARK. CODE ANN. § 5-14-125(a)(6)&(b)(1). The said defendant in the FIRST Division of SCOTT COUNTY, did unlawfully and feloniously on or about March 1, 2013 and July 31, 2014.

5-14-125. Sexual assault in the second degree.

(a) A person commits sexual assault in the second degree if the person:

(1) Engages in sexual contact with another person by forcible compulsion;

(3) Being eighteen (18) years of age or older, engages in sexual contact with another person who is:

(A) Less than fourteen (14) years of age; and

(B) Not the person’s spouse;

(4)(A) Engages in sexual contact with a minor and the actor is:

(iii) The minor’s guardian, an employee in the minor’s school or school district, a temporary caretaker, or a person in a position of trust or authority over the minor.

(B) For purposes of subdivision (a)(4)(A) of this section, consent of the minor is not a defense to a prosecution;

(b)(1) Sexual assault in the second degree is a Class B felony.

Thereby committing the offense of Sexual Assault, Second Degree (8/16/2013 and thereafter), said offense being a CLASS B FELONY against the peace and dignity of the State of Arkansas.

COUNT 2: Sexual Assault, Second Degree (8/16/2013 and thereafter) ARK. CODE ANN. § 5-14-125(a)(6)&(b)(1). The said defendant in the FIRST

1 The August 16, 2013, date in the amended information is a reference to the effective date of the 2013 version of the second-degree sexual-assault statute. Previous versions of the second-degree sexual-assault statute contain similar language.

3 Division of SCOTT COUNTY, did unlawfully and feloniously on or about January 1, 2003 and February 11, 2014.

(a) A person commits sexual assault in the second degree if the person:

(1) Engages in sexual contact with another person by forcible compulsion;

(3) Being eighteen (18) years of age or older, engages in sexual contact with another person who is:

(4)(A) Engages in sexual contact with a minor and the actor is:

(iii) The minor’s guardian, and employee in the minor’s school or school district, a temporary caretaker, or a person in a position of trust or authority over the minor.

(B) For purposes of subdivision (a)(4)(A) of this section, consent of the minor is not a defense to a prosecution;

(b)(1) Sexual assault in the second degree is a Class B felony.

Thereby committing the offense of Sexual Assault, Second Degree (8/16/2013 and thereafter), said offense being a CLASS B FELONY against the peace and dignity of the State of Arkansas.

As will become more relevant in our discussion infra of the points raised in this appeal,

the October 25, 2019, amended information differs in two important respects from the

September 23, 2015, information that was filed prior to the first trial in this case. In the

bold print following each “COUNT,” the 2015 information referenced “Ark. Code Ann.

§ 5-14-125(a)(1), (3)(A), (4)(A)(iii) & (b)(1),” whereas the 2019 amended information

references “Ark. Code Ann. § 5-14-125(a)(6) and (b)(1).” (Emphasis added.) It is

4 undisputed that subdivision (a)(6) of the second-degree sexual-assault statute has no

application to this case, and it provides:

(a) A person commits sexual assault in the second degree if the person:

....

(6) Is a teacher, principal, athletic coach, or counselor in a public or private school in a grade kindergarten through twelve (K-12), in a position of trust or authority, and uses his or her position of trust or authority over the victim to engage in sexual contact with a victim who is:

(A) A student enrolled in the public or private school; and

(B) Less than twenty-one (21) years of age.

Ark. Code Ann. § 5-14-125(a)(6) (Repl. 2013). The other difference between the criminal

informations is that the 2015 information alleged that the separate offenses occurred on or

about “March 1, 2013 through July 31, 2014” and “January 1, 2003 through February 11,

2014,” whereas the 2019 amended information alleged that the separate offenses occurred

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2021 Ark. App. 298, 626 S.W.3d 154, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-n-bynum-v-state-of-arkansas-arkctapp-2021.