Shannon Thepharath v. State of Arkansas

2024 Ark. App. 171, 686 S.W.3d 840
CourtCourt of Appeals of Arkansas
DecidedMarch 6, 2024
StatusPublished

This text of 2024 Ark. App. 171 (Shannon Thepharath 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
Shannon Thepharath v. State of Arkansas, 2024 Ark. App. 171, 686 S.W.3d 840 (Ark. Ct. App. 2024).

Opinion

Cite as 2024 Ark. App. 171 ARKANSAS COURT OF APPEALS DIVISION III No. CR-23-418

Opinion Delivered March 6, 2024 SHANNON THEPHARATH APPELLANT APPEAL FROM THE PULASKI COUNTY CIRCUIT COURT, THIRD DIVISION V. [NO. 60CR-19-4619]

STATE OF ARKANSAS HONORABLE CATHLEEN V. APPELLEE COMPTON, JUDGE AFFIRMED

WENDY SCHOLTENS WOOD, Judge

Shannon Thepharath brings this interlocutory appeal from an order of the Pulaski

County Circuit Court denying her motion to dismiss a third-degree domestic-battering

charge. On appeal, Thepharath argues that the circuit court erred in denying her motion

because a retrial of the domestic-battering charge is barred by double jeopardy. We affirm

the circuit court’s denial of the motion to dismiss.

This case arose from an incident that occurred on September 10, 2019, involving

Thepharath and her then seventeen-year-old son (“minor victim”). Thepharath was charged

with aggravated assault of a family or household member (a Class D felony) and third-degree

domestic battering (a Class A misdemeanor). A jury trial took place on July 19, 2022. The

jury acquitted Thepharath of aggravated assault of a family or household member but was

deadlocked on the domestic-battering charge. The circuit court declared a mistrial. When the State informed the court that it intended to retry the domestic-battering charge,

Thepharath moved to dismiss on double-jeopardy grounds.

In a January 5, 2023 order, the circuit court denied Thepharath’s motion to dismiss,

finding that double jeopardy did not bar a retrial of the domestic-battering charge. The court

found that each of the charges required proof of an element that the other did not.

Specifically, aggravated assault of a family member as charged by the State required a finding

of an impediment of air or circulation, and domestic battering required a finding of physical

injury. The circuit court explained:

In the instant case, exhibits and evidence at trial demonstrated that “choking” of the Defendant was not the only possible injury the jury could find, but that scratches on the back of the victim and also his arms were evident. That alone is a “physical injury” required by 3rd Degree Domestic Battery, which is not “choking” as required by Aggravated Assault of a Family or Household Member. Moreover testimony existed regarding the physical struggles between the victim and the Defendant—it is for a jury to determine if those interactions, based on testimony and the photo evidence, resulted in physical injury that would warrant a finding of physical injury. The first jury could not come to a determination on that issue. A second jury may be able to.

This appeal followed.

In Williams v. State, 371 Ark. 550, 553, 268 S.W.3d 868, 871 (2007), the supreme

court set out the applicable standard of review:

This court reviews a circuit court’s denial of a motion to dismiss on double- jeopardy grounds de novo. See Winkle v. State, 366 Ark. 318, 235 S.W.3d 482 (2006). We have further said that “when the analysis presents itself as a mixed question of law and fact, the factual determinations made by the trial court are given due deference and are not reversed unless clearly erroneous.” Id. at 320, 235 S.W.3d at 483. However, the ultimate decision by the circuit court that the defendant’s protection against double jeopardy was not violated is reviewed de novo, with no deference given to the circuit court’s determination. Id. A double-jeopardy claim may be raised by interlocutory appeal because if a defendant is illegally tried a second time,

2 the right would have been forfeited. See Zawodniak v. State, 339 Ark. 66, 3 S.W.3d 292 (1999). The Fifth Amendment to the United States Constitution and article 2, section 8 of

the Arkansas Constitution require that no person be twice put in jeopardy of life or liberty

for the same offense. The Double Jeopardy Clause protects criminal defendants from (1) a

second prosecution for the same offense after acquittal, (2) a second prosecution for the

same offense after conviction, and (3) multiple punishments for the same offense. Campbell

v. State, 2017 Ark. App. 340, at 7–8, 525 S.W.3d 465, 470. In order to determine whether

the same act violates two separate statutory provisions, we apply the same-elements test,

commonly referred to as the Blockburger test, which states as follows:

[W]here the same act or transaction constitutes a violation of two distinct statutory provisions, the test to be applied to determine whether there are two offenses or only one, is whether each provision requires proof of a fact which the other does not. . . . “A single act may be an offense against two statutes; and if each statute requires proof of an additional fact which the other does not, an acquittal or conviction under either statute does not exempt the defendant from prosecution and punishment under the other.”

Blockburger v. United States, 284 U.S. 299, 304 (1932) (quoting Morey v. Commonwealth, 108

Mass. 433, 434 (1871)). The Arkansas General Assembly has codified this constitutional

protection at Arkansas Code Annotated section 5-1-110(b) (Repl. 2013), which provides that

an offense is included in an offense charged if the offense is established by proof of the same

or less than all the elements required to establish the commission of the offense charged.

Thepharath argues that the circuit court erred in denying her motion to dismiss the

domestic-battering charge because double jeopardy bars prosecution. She contends that the

State has accused her of one wrong—choking a family member—but charged her with two

3 different offenses. Thepharath asserts that in retrying the domestic-battering charge, the State

will have to reargue that she choked her son, and a jury has already found that she did not

choke her son and acquitted her of aggravated assault. Thepharath argues that the State’s

allegations fail the Blockburger test because, although the aggravated-assault count included

elements not found in the domestic-battering count, third-degree domestic battering does

not contain any additional element that is not required for aggravated assault as charged.

We disagree.

The State charged Thepharath with aggravated assault of a family member under

Arkansas Code Annotated section 5-26-306(a)(3) (Supp. 2023), which required the State to

prove that, under circumstances manifesting extreme indifference to the value of human life,

Thepharath purposely impeded or prevented the respiration of the family or household

member or the circulation of a family or household member’s blood by applying pressure on

the chest, throat, or neck or by blocking the nose or mouth of the family or household

member. The State also charged Thepharath with third-degree domestic battering under

Arkansas Code Annotated section 5-26-305(a)(1) (Supp. 2023), which required the State to

prove that Thepharath, with the purpose of causing physical injury to a family or household

member, caused physical injury to a family or household member. The criminal information

did not allege specific facts as to how the domestic battering occurred.

Here, the aggravated-assault charge requires proof of impeding or preventing the

respiration of a family or household member or circulation of a family or household

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Related

Blockburger v. United States
284 U.S. 299 (Supreme Court, 1931)
Richardson v. United States
468 U.S. 317 (Supreme Court, 1984)
Winkle v. State
235 S.W.3d 482 (Supreme Court of Arkansas, 2006)
Williams v. State
268 S.W.3d 868 (Supreme Court of Arkansas, 2007)
Zawodniak v. State
3 S.W.3d 292 (Supreme Court of Arkansas, 1999)
Campbell v. State
2017 Ark. App. 340 (Court of Appeals of Arkansas, 2017)
Hannah v. State
2019 Ark. App. 252 (Court of Appeals of Arkansas, 2019)
Morey v. Commonwealth
108 Mass. 433 (Massachusetts Supreme Judicial Court, 1871)
Gallagher v. City of Van Buren
786 S.W.2d 837 (Court of Appeals of Arkansas, 1990)
John Mitchell v. State of Arkansas
2023 Ark. App. 119 (Court of Appeals of Arkansas, 2023)

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2024 Ark. App. 171, 686 S.W.3d 840, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shannon-thepharath-v-state-of-arkansas-arkctapp-2024.