Mario Lopez Perea, Jr. v. State of Arkansas

2019 Ark. App. 322
CourtCourt of Appeals of Arkansas
DecidedJune 5, 2019
StatusPublished
Cited by1 cases

This text of 2019 Ark. App. 322 (Mario Lopez Perea, Jr. 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
Mario Lopez Perea, Jr. v. State of Arkansas, 2019 Ark. App. 322 (Ark. Ct. App. 2019).

Opinion

Cite as 2019 Ark. App. 322 ARKANSAS COURT OF APPEALS Digitally signed by Elizabeth Perry DIVISION II Date: 2022.07.21 12:43:04 -05'00' No. CR-18-666 Adobe Acrobat version: 2022.001.20169 Opinion Delivered: June 5, 2019

MARIO LOPEZ PEREA, JR. APPELLANT APPEAL FROM THE BENTON COUNTY CIRCUIT COURT V. [NO. 04CR-17-292]

STATE OF ARKANSAS APPELLEE HONORABLE BRAD KARREN, JUDGE

REBRIEFING ORDERED; MOTION TO WITHDRAW DENIED

BART F. VIRDEN, Judge

A Benton County jury convicted appellant Mario Lopez Perea, Jr., of attempted

sexual assault in the second degree. He was sentenced as a habitual offender to twenty years’

imprisonment. Counsel has filed a no-merit brief pursuant to Anders v. California, 386 U.S.

738 (1967), and Arkansas Supreme Court Rule 4-3(k), along with a motion to withdraw.

In accordance with Rule 4-3(k)(2), the clerk of this court furnished Perea with a copy of

counsel’s brief and informed him of his right to file pro se points for reversal. Perea filed pro

se points, and the State has responded. Because counsel’s no-merit brief does not comply

with Anders and Rule 4-3(k), we deny her motion to withdraw and order rebriefing to give

her an opportunity to cure any deficiencies. We thus order counsel to file a substituted

abstract, addendum, and brief within fifteen days of the date of this opinion. I. Procedural Background

Perea was charged with second-degree sexual assault under Ark. Code Ann. § 5-14-

125(a)(1) (Supp. 2017), which provides that a person commits sexual assault in the second

degree if the person engages in sexual contact with another person by forcible compulsion.

There were several pretrial hearings, including arraignment hearings, an omnibus hearing,

pretrial status hearings, and a motions hearing. A jury trial was held on December 11 and

12, 2017.

The State introduced testimony by the victim, her grandfather, and her mother. The

State also presented the testimony of several law enforcement officers, and a video of an

interview between police and Perea was played for the jury. After the State rested, trial

counsel moved for a directed verdict, which was denied.

Perea testified in his own defense. Trial counsel then renewed his directed-verdict

motion, which was again denied. The jury found Perea guilty of the lesser-included offense

of attempted sexual assault in the second degree.

During the sentencing phase, the trial court read a jury instruction regarding Perea’s

habitual-offender status and then read the four prior felony convictions into the record.

There was no objection by trial counsel. The State introduced victim-impact statements,

and Perea introduced two photos of him with small children. The jury fixed Perea’s sentence

at twenty years’ imprisonment with no fine. The trial court sentenced Perea in accordance

with the jury’s verdict.

Trial counsel, on Perea’s behalf, filed a timely notice of appeal from the conviction.

Trial counsel’s subsequent motion to withdraw was granted, and appellate counsel was

2 appointed to represent Perea. Appellate counsel has filed a motion to withdraw on the basis

that the appeal is wholly without merit.

II. Counsel’s No-Merit Brief

A request to withdraw on the ground that the appeal is wholly without merit shall

be accompanied by a brief including an abstract and addendum. Ark. Sup. Ct. R. 4-3(k)(1).

The brief must contain an argument section that consists of a list of all rulings adverse to the

defendant made by the trial court on all objections, motions, and requests with an

explanation as to why each adverse ruling is not a meritorious ground for appeal. Id. In

deciding whether to allow counsel to withdraw from appellate representation, the test is not

whether counsel thinks the trial court committed no reversible error, but rather whether

the points to be raised on appeal would be wholly frivolous. Eads v. State, 74 Ark. App.

363, 47 S.W.3d 918 (2001). We are required to determine whether the case is wholly

frivolous after a full examination of all the proceedings. Vail v. State, 2019 Ark. App. 8.

Counsel asserts that there were three adverse rulings, including the denial of Perea’s

motion for a directed verdict; however, we found only two adverse rulings in the record.

At a pretrial status hearing, Perea sought to introduce evidence of the victim’s past

“behavior problems” and evidence that she had sent “inappropriate” Snapchat photos. The

trial court denied the request. The other adverse ruling was the trial court’s denial of Perea’s

directed-verdict motion.

Counsel asserts that another adverse ruling occurred during sentencing when the trial

court admitted Perea’s four prior felony convictions into evidence, even though some of

them were more than ten years old. As noted in the procedural-background section, trial

counsel made no objection to the admission of Perea’s prior felony convictions at 3 sentencing. Appellate counsel’s reference in her brief to convictions more than ten years old

has to do with an unrelated ruling that occurred during the guilt phase. After the State had

rested, the prosecutor sought to admit one of Perea’s prior convictions that was less than ten

years old for impeachment purposes based on Perea’s anticipated testimony. The trial court

referred to Ark. R. Evid. 609 and sustained trial counsel’s objection because the trial court

found that admission of a drug conviction for impeachment purposes was not more

probative than prejudicial. The ruling in the guilt phase was not adverse to Perea, and there

was no ruling during the sentencing phase because trial counsel did not object to the

introduction of Perea’s prior felony convictions.

A. Abstracting Issues

All material information recorded in a transcript must be abstracted. Ark. Sup. Ct.

R. 4-2(a)(5)(A). Information in a transcript is material if it is essential for the appellate court

to confirm its jurisdiction, to understand the case, and to decide the issues on appeal. Ark.

Sup. Ct. R. 4-2(a)(5). The abstract shall be an impartial condensation, without comment or

emphasis, of the transcript. Ark. Sup. Ct. R. 4-2(a)(5)(B).

Counsel subjectively summarizes what occurred at the pretrial hearings. In particular,

at the second pretrial status hearing on December 11, 2017, the trial court granted the State’s

motion in limine to prevent the defense from introducing testimony concerning the victim’s

past “behavior problems,” including evidence that she had sent “inappropriate” Snapchat

photos. The trial court ruled that the testimony was inadmissible on several bases, including

relevance and the rape-shield statute.

The abstract of a pretrial status hearing at which an adverse ruling was made should

be an impartial condensation of the record—not appellate counsel’s impression of what 4 occurred. See Schernikau v. Williamson, 2018 Ark. App. 34, at 6, 540 S.W.3d 710, 713

(finding abstract deficient in that it was not an “impartial condensation” because “it appears

to consist mainly of a general summary of the arguments of counsel and colloquies between

counsel and the court, with the writer’s impressions of what was transpiring at the hearing

and commentary thereon”). Moreover, we note that appellate counsel mentions in the

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Related

Mario Lopez Perea, Jr. v. State of Arkansas
2019 Ark. App. 426 (Court of Appeals of Arkansas, 2019)

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