Ricky Allen Williams v. State of Arkansas

2023 Ark. App. 48, 660 S.W.3d 323
CourtCourt of Appeals of Arkansas
DecidedFebruary 8, 2023
StatusPublished

This text of 2023 Ark. App. 48 (Ricky Allen Williams 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
Ricky Allen Williams v. State of Arkansas, 2023 Ark. App. 48, 660 S.W.3d 323 (Ark. Ct. App. 2023).

Opinion

Cite as 2023 Ark. App. 48 ARKANSAS COURT OF APPEALS DIVISION II No. CR-22-214

RICKY ALLEN WILLIAMS Opinion Delivered February 8, 2023 APPELLANT APPEAL FROM THE LONOKE COUNTY CIRCUIT COURT V. [NO. 43CR-21-165]

STATE OF ARKANSAS HONORABLE BARBARA ELMORE, APPELLEE JUDGE

AFFIRMED

CINDY GRACE THYER, Judge

Ricky Allen Williams was convicted by a jury in the Lonoke County Circuit Court of

second-degree murder in the shooting death of John Harp. Williams was sentenced to a total of

seventy-five years’ imprisonment in the Arkansas Department of Correction.1 Williams appeals,

arguing that the evidence was insufficient to rebut his justification defense. Because his

argument is not preserved for appeal, we affirm.

The basic facts are undisputed. Williams and Harp were childhood friends who had not

seen each other for many years. They eventually reconnected through social media. On February

3, 2021, Harp and his friend, Khanh Tran, visited Williams at the home Williams shared with

his mother in Ward, Arkansas. Williams was working on some vehicles at a barn on his property

1 Williams was sentenced to sixty years’ imprisonment on the second-degree murder charge with a consecutive fifteen-year sentence on a felony-firearm enhancement that was ordered to run consecutively. when Harp and Tran arrived. While visiting Williams, Harp became intoxicated. Williams asked

Harp to leave the property, and when Harp refused, Williams shot Harp. Harp collapsed, and

Williams’s mother and a neighbor placed Harp in Tran’s car. Tran then drove Harp to the

halfway house where they lived in Little Rock. Several hours later, Harp was discovered

unresponsive in Tran’s vehicle. Emergency personnel were dispatched and later took Harp to

the hospital where he was pronounced dead from a gunshot wound. Williams was charged by

information with first-degree murder.

At trial, Williams argued that the shooting was justified because Harp was sexually

accosting his mother when he shot Harp. The State disagreed. It argued that Williams’s mother’s

claims that Harp had physically attacked her were not credible. Instead, the State asserted that

Williams had shot Harp, not because he had attacked his mother, but because Harp had

disrespected him. The State also noted that, rather than retrieving a gun to resolve the dispute,

Williams could have called the police but did not do so.

At the close of all the evidence, the court instructed the jury on first-degree murder as

well as the lesser-included offenses of second-degree murder and manslaughter. The court also

instructed the jury on the justification defense as to first-degree murder. After deliberations, the

jury convicted Williams of the lesser-included offense of second-degree murder.

Williams’s only argument on appeal is a challenge to the sufficiency of the State’s

evidence negating his justification defense. More specifically, Williams asserts that the trial court

was misled by the prosecutor’s claim that justification was an affirmative defense, which resulted

in the burden of proof being improperly shifted to him.

2 Williams, however, never objected to the State’s characterization of the justification

defense as an affirmative defense, nor did he ever raise his improper burden-shifting argument

below. We will not consider arguments that are raised for the first time on appeal, including

constitutional arguments. Sirkaneo v. State, 2022 Ark. 124, 644 S.W.3d 392; Armstrong v. State,

2020 Ark. 309, 607 S.W.3d 491. As such, to the extent Williams argues that there was an

improper shifting of the burden of proof, his argument is not preserved for appeal.

To the extent he argues the actual merits of his sufficiency argument, that argument is

also not preserved for appeal. At the close of the State’s case, Williams moved for directed

verdict, arguing that the State had not met its burden of proof with respect to the elements of

first-degree murder and that he was entitled to a directed verdict on his justification defense.

The motion was denied. He renewed his motion for directed verdict at the close of all of the

evidence and urged the court to declare as a matter of law that the jury find justification. The

motion was again denied. The jury subsequently found appellant guilty of the lesser-included

offense of second-degree murder.

As stated above, Williams argues on appeal that the State failed to provide sufficient

evidence of second-degree murder because it failed to negate his justification defense. However,

his directed verdict motions at trial challenged the sufficiency of the evidence with regard to

first-degree murder, not second-degree murder, and therefore any argument as to the sufficiency

of the evidence on the lesser-included offense has been waived.

This court has held that in order to preserve challenges to the sufficiency of the evidence

supporting convictions for lesser-included offenses, defendants must address the lesser-included

offenses either by name or by apprising the trial court of the elements of the lesser-included

3 offenses questioned by their motions for directed verdict. Grillot v. State, 353 Ark. 294, 107

S.W.3d 136 (2003). Williams’s directed-verdict motion did not include the lesser-included

offense of second-degree murder, either in name or in elements. Accordingly, his argument is

not preserved for appellate review. See Rasul v. State, 2009 Ark. App. 631; see also Mainard v. State,

102 Ark. App. 210, 283 S.W.3d 627 (2008) (holding that appellant could not raise his

justification defense on appeal of his second-degree-murder conviction because he had not

included that lesser-included offense, either by name or elements, in his motions to the trial

court).

Even if we were to reach the merits of Williams’s sufficiency argument, we would affirm

on that basis as well. The test for determining the sufficiency of the evidence is whether the

verdict is supported by substantial evidence, direct or circumstantial. Scott-Paxson v. State, 2015

Ark. App. 149, at 1, 457 S.W.3d 311, 312. When a defendant challenges the sufficiency of the

evidence that led to a conviction, the evidence is viewed in the light most favorable to the State.

Id., 457 S.W.3d at 312. Only evidence supporting the verdict will be considered. Id., 457 S.W.3d

at 312. We also employ the substantial-evidence standard of review when reviewing the

sufficiency of the State’s negation of a justification defense. Brown v. State, 2020 Ark. App. 198,

595 S.W.3d 456; Gillard v. State, 2019 Ark. App. 438, 586 S.W.3d 703.

We note that justification is not an affirmative defense that must be pleaded but becomes

a defense when any evidence tending to support its existence is offered to support it. Schnarr v.

State, 2018 Ark. 333, at 10, 561 S.W.3d 308, 314–15. The State has the burden of negating the

defense once it is put in issue. Humphrey v. State, 332 Ark. 398, 409, 966 S.W.2d 213, 218 (1998).

4 Justification is considered an element of the offense, and once raised, it must be disproved by

the State beyond a reasonable doubt. Ark. Code Ann. § 5-1-102(5)(C) (Supp. 2021); Anderson v.

State, 353 Ark. 384, 404, 108 S.W.3d 592

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Related

Anderson v. State
108 S.W.3d 592 (Supreme Court of Arkansas, 2003)
Grillot v. State
107 S.W.3d 136 (Supreme Court of Arkansas, 2003)
Brunson v. State
245 S.W.3d 132 (Supreme Court of Arkansas, 2006)
Mainard v. State
283 S.W.3d 627 (Court of Appeals of Arkansas, 2008)
Humphrey v. State
966 S.W.2d 213 (Supreme Court of Arkansas, 1998)
Moody v. State
2014 Ark. App. 538 (Court of Appeals of Arkansas, 2014)
Lewis v. State
2014 Ark. App. 730 (Court of Appeals of Arkansas, 2014)
Scott-Paxson v. State
2015 Ark. App. 149 (Court of Appeals of Arkansas, 2015)
Luper v. State
2016 Ark. 371 (Supreme Court of Arkansas, 2016)
Schnarr v. State
561 S.W.3d 308 (Supreme Court of Arkansas, 2018)
Qatonious Sirkaneo A/K/A Walter Allen Brooks v. State of Arkansas
2022 Ark. 124 (Supreme Court of Arkansas, 2022)
Tanisha Gillard v. State of Arkansas
2019 Ark. App. 438 (Court of Appeals of Arkansas, 2019)
Adam Brown v. State of Arkansas
2020 Ark. App. 198 (Court of Appeals of Arkansas, 2020)
Matthew Armstrong v. State of Arkansas
2020 Ark. 309 (Supreme Court of Arkansas, 2020)

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2023 Ark. App. 48, 660 S.W.3d 323, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ricky-allen-williams-v-state-of-arkansas-arkctapp-2023.