Kenneth King v. State of Arkansas

2025 Ark. App. 335
CourtCourt of Appeals of Arkansas
DecidedMay 28, 2025
StatusPublished

This text of 2025 Ark. App. 335 (Kenneth 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
Kenneth King v. State of Arkansas, 2025 Ark. App. 335 (Ark. Ct. App. 2025).

Opinion

Cite as 2025 Ark. App. 335 ARKANSAS COURT OF APPEALS DIVISION II No. CR-24-661

KENNETH KING Opinion Delivered May 28, 2025

APPELLANT APPEAL FROM THE WHITE COUNTY CIRCUIT COURT V. [NO. 73CR-23-570]

STATE OF ARKANSAS HONORABLE MARK PATE, JUDGE APPELLEE AFFIRMED

CASEY R. TUCKER, Judge

Kenneth King appeals his conviction of driving while intoxicated—drugs (DWI) at the

conclusion of a bench trial in the White County Circuit Court. On appeal, he asserts that

the trial court erred in denying his motion for directed verdict. We affirm.

Generally, in a bench trial, a motion for directed verdict is treated as a motion to

dismiss. Ark. R. Crim. P. 33.1; Colen v. State, 2022 Ark. App. 148, 643 S.W.3d 274. “A

motion to dismiss at a bench trial is identical to a motion for directed verdict at a jury trial

in that it is a challenge to the sufficiency of the evidence.” Harding v. State, 2024 Ark. App.

560, at 3, 700 S.W.3d 521, 523. The appellate court will affirm the trial court’s decision if

there is substantial evidence to support the verdict. Id. Substantial evidence is defined as

evidence that compels a conclusion beyond suspicion and conjecture. Porter v. State, 2023

Ark. App. 64, 660 S.W.3d 875. On appeal, the evidence is viewed in the light most favorable to the verdict, and we consider only that evidence that supports the verdict. Cottrell v. State,

2024 Ark. App. 175, 686 S.W.3d 582. This court does not weigh the evidence or assess the

credibility of witnesses because these are matters for the fact-finder. Id.

Viewed in the light most favorable to the verdict, the evidence at the bench trial was

as follows. On January 5, 2022, White County Deputy Sheriff Garrett Walters stopped King

after he failed to yield at a stop sign, and Walters had to hit his brakes to avoid a collision.

While conducting the stop, Deputy Walters smelled the odor of marijuana coming from

King’s car. Deputy Walters obtained King’s driver’s license, registration, and insurance

documents and ran his information through the Crime Information Center system. When

he did so, he found that King had a search waiver on file. Upon questioning, King told

Deputy Walters that he did not have any marijuana and had not smoked it recently. Deputy

Walters had King exit the vehicle and began conducting field sobriety tests on him.

Deputy Walters is certified in ARID––Advanced Roadside Impairment Detection––

for DWIs and DUIs. At one time, he was a certified drug recognition expert, but he had let

that certification expire before he stopped King. Deputy Walters put King through the

horizontal-gaze-nystagmus test (the HGN), the walk-and-turn test, and the one-leg-stand test.

King showed no clues of impairment in response to the HGN, which, according to Deputy

Walters, is consistent with marijuana use. Deputy Walters testified that King showed three

clues of impairment during the walk-and-turn test: (1) he missed a heel-to-toe step; (2) he did

not conduct the turn properly; and (3) he stepped off the imaginary line on which he was

walking. During the one-leg-stand test, King again exhibited signs of impairment in that he

2 swayed, used his arms for balance, and had to put a foot down. After conducting the first

three tests and observing clues, Deputy Walters conducted a lack-of-convergence test. In this

test, the officer tells the driver to keep his eyes on his finger, then circles his finger around

the driver’s face and eventually moves the finger almost to the driver’s nose. The driver’s

inability to converge, or cross, his eyes aids the tester in narrowing down what kind of drug

the driver has used. King was unable to cross his eyes. Deputy Walters acknowledged that

not everyone can cross their eyes, even when sober. At the scene, King told Deputy Walters

that he did not know whether he could cross his eyes because he had never tried. The dash-

camera video and Deputy Walters’s body-camera video, both of which captured the field

sobriety tests, were played for the court and entered in the record.

While Deputy Walters was conducting field sobriety tests, other officers searching

King’s car found marijuana. After completing the field sobriety tests, King admitted that he

had gotten marijuana from a friend, and he might have had one hit earlier while at his

friend’s house. Deputy Walters took King to the station where King gave a urine sample.

The sample tested positive for marijuana; however, as acknowledged by Walters, a positive

urine sample of the type conducted does not indicate when the marijuana was ingested, how

much was ingested, or whether the person is currently under the influence. Before giving

the urine sample, King told Deputy Walters that he would probably test positive because he

had smoked marijuana the day before.

3 King moved for a directed verdict, which the court denied. The court found King

guilty of DWI—drugs and sentenced him to fifteen days in the county jail and a fine of

$1,000. King filed a timely notice of appeal.

It is unlawful to drive a motor vehicle while intoxicated. Ark. Code Ann. § 5-65-

103(a)(1) (Repl. 2024). “Intoxicated” means influenced or affected by the ingestion of

alcohol, a controlled substance, any intoxicant, or any combination of alcohol, a controlled

substance, or an intoxicant, to such a degree that the driver’s reactions, motor skills, and

judgment are substantially altered and the driver, therefore, constitutes a clear and

substantial danger of physical injury or death to himself or herself or another person.” Ark.

Code Ann. § 5-65-102(4) (Repl. 2024). Opinion testimony on whether an individual is

intoxicated is admissible, and it is the fact-finder’s role to determine the testimony’s weight

and credibility. Roger v. State, 2024 Ark. App. 340, 690 S.W.3d 465; Mace v. State, 328 Ark.

536, 944 S.W.2d 830 (1997). An officer’s observations of a driver while going through field

sobriety tests constitute competent evidence supporting a DWI charge. Id.

Here, Deputy Walters’s testimony was that King either ran or failed to yield at a stop

sign and exhibited multiple signs of intoxication during the field sobriety tests—namely, the

walk-and-turn test and the one-leg-stand test. And while King could not cross his eyes on the

lack-of-convergence test, he did not have a problem performing the HGN test. Deputy

Walters testified that the combination of these results is indicative of intoxication from

ingestion of marijuana.

4 King asserts that Robinson v. State, 98 Ark. App. 237, 254 S.W.3d 750 (2007), is

applicable in the present case. We disagree. In Robinson, this court held that the circuit

court erred in finding sufficient evidence of intoxication, reducing the appellant’s conviction

from Class C felony negligent homicide to Class A misdemeanor negligent homicide. Tests

on the appellant’s blood and urine were positive for various drugs. However, they were

inconclusive as to when the drugs were ingested and whether the appellant was under the

influence when she caused a fatal collision. The same can be said of the test performed on

King’s urine sample in the case before us. However, the cases are distinguishable in that in

Robinson, neither the officers on the scene of the collision nor the appellant’s coworkers who

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Related

Robinson v. State
254 S.W.3d 750 (Court of Appeals of Arkansas, 2007)
MacE v. State
944 S.W.2d 830 (Supreme Court of Arkansas, 1997)
Morton v. State
384 S.W.3d 585 (Court of Appeals of Arkansas, 2011)
Tracy Cottrell v. State of Arkansas
2024 Ark. App. 175 (Court of Appeals of Arkansas, 2024)
Jason Harding v. State of Arkansas
2024 Ark. App. 560 (Court of Appeals of Arkansas, 2024)
George Reece v. State of Arkansas
2025 Ark. App. 68 (Court of Appeals of Arkansas, 2025)

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2025 Ark. App. 335, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kenneth-king-v-state-of-arkansas-arkctapp-2025.