Shawn Harness v. State of Arkansas

2022 Ark. App. 360
CourtCourt of Appeals of Arkansas
DecidedSeptember 28, 2022
StatusPublished
Cited by1 cases

This text of 2022 Ark. App. 360 (Shawn Harness 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
Shawn Harness v. State of Arkansas, 2022 Ark. App. 360 (Ark. Ct. App. 2022).

Opinion

Cite as 2022 Ark. App. 360 ARKANSAS COURT OF APPEALS DIVISION I No. CR-22-66

SHAWN HARNESS OPINION DELIVERED SEPTEMBER 28, 2022 APPELLANT APPEAL FROM THE BOONE COUNTY CIRCUIT COURT V. [NO. 05CR-19-305]

STATE OF ARKANSAS HONORABLE JOHN R. PUTMAN, APPELLEE JUDGE

AFFIRMED

ROBERT J. GLADWIN, Judge

Shawn Harness was convicted of rape in the Boone County Circuit Court, and in

this appeal, he argues that the circuit court erred by denying his motions for mistrial. We

affirm.

I. Facts

Harness was charged with rape by criminal information filed on July 22, 2019, and

he pled not guilty. On September 27, 2021, he was tried by a jury, and the victim testified

that she and Harness had been in a dating relationship and moved into an apartment

together, having separate bedrooms. She said that on three occasions, Harness forcibly held

her down and raped her, penetrating her vagina with his penis. The State introduced a

recorded conversation between the victim and Harness wherein Harness stated that he

guaranteed that it would not happen again, that he thought it was not “an issue,” and that he did not “plan ahead for everything.” Detective Ted Shaeffer testified that he interviewed

Harness, who confessed to the first rape, and the recorded interview was played for the jury.

The subject of Harness’s appeal surrounds two objections that occurred during the

victim’s testimony. Harness’s counsel inquired about the victim’s communication with the

victim witness coordinator. The following colloquy occurred:

Q Did y’all talk last night?

A Yes.

Q What’d y’all talk about?

A She asked if I was doing okay. She said, like, if I needed anything—we went over a couple of things so that I would be—I wouldn’t have a meltdown up here.

Q When you say you went over a couple things, what’d you go over?

A She asked me to go through a couple of spots that she had questions about, and so I told her my part of it again.

Q What part did she have questions about?

A There was a couple of questions about the meme. She asked, like, why did I send it, basically. She asked if I ever, like, had a safe word or anything like that.

Q Okay. What else did you talk about? This was last night; correct?

Q Where were you at when you were talking?

A We talked here, and then she called me when I got home because she had a couple of those questions.

Thereafter, Harness’s counsel moved for a mistrial as follows:

2 I guess—I think I need to ask for a mistrial because it sounds like the State’s victim coordinator is going through after the trial started, after I began opening, eliciting details, and having the witness clear up some spots in her testimony. I think that’s a violation of the rule where the trial had started. If the trial coor—the victim coordinator was in here, was taking notes during my opening, and now has gone through and addressed those after the trial began with the State’s key—and basically the crux of the case. I think that it’s—I don’t want to call it witness tampering because I believe that’s a crime, but I think this is an issue where I need to—I am entitled to— if they’re continuing to investigate the case, I’m entitled to the discovery of the answers that she gave the trial coordinator. She is not a prosecutor. It is not work product. It is an investigation that the State is doing that I’m entitled to the answers and the notes that she’s taking. I think it violates the rule, and I think the Court should declare a mistrial.

After further argument, Harness’s counsel added, “I object to the witness, or the victim,

sitting at counsel table as the jury came back from lunch. The victim was sitting at counsel

table when the jury walked in and there’s case law that says that’s impermissible and

reversible error.”

The court ruled and Harness’s counsel responded as follows:

THE COURT: . . . I had taken under submission the issue about communication between the victim/witness coordinator and the alleged victim after the start of the trial. I’m just going to let that go to the weight. I’m going to deny the motion for a mistrial, and I’ll let you argue it in close or at the appropriate time. And in regard to when the victim sat down at the prosecutor’s table, and I think we should note that there are two tables, one behind the other here, and I can give a limiting instruction that she’s not a part of the—the that the alleged victim is not a part of the prosecution team, if you want that—you might not want it for strategic reasons, but--

DEFENSE COUNSEL: Judge, that’s—I guess as long as we refrain from going any further than what’s happened I think that’s—that’s enough. I think the encounter was short enough that it wasn’t something that jumped out--

3 The jury found Harness guilty and sentenced him to 120 months’ imprisonment, and

this timely appeal followed.

II. Mistrial Motion Regarding Discovery

The decision to grant or deny a motion for mistrial is within the sound discretion of

the circuit court and will not be overturned absent a showing of abuse or manifest prejudice

to the appellant. Maiden v. State, 2014 Ark. 294, at 10, 438 S.W.3d 263, 271. A mistrial is

a drastic remedy and should be declared only when there is error so prejudicial that justice

cannot be served by continuing the trial, and when it cannot be cured by an instruction to

the jury. Id. With respect to motions for mistrial based on Arkansas Rule of Criminal

Procedure 17.1 (2021), we have observed that a mistrial is an extreme sanction for a

prosecutorial discovery violation and is to be avoided unless the fundamental fairness of the

trial itself is at stake. Id.

Rule 17.1(d) provides that the prosecuting attorney shall, promptly upon discovering

the matter, disclose to defense counsel any material or information within his knowledge,

possession, or control, which tends to negate the guilt of the defendant as to the offense

charged or would tend to reduce the punishment therefor. Arkansas Rule of Criminal

Procedure 19.2 (2021) contains a continuing duty to disclose, and Rule 19.4 provides that

upon a showing of cause, the court may at any time order that specified disclosures be

restricted or deferred, or make such other order as is appropriate, provided that all material

4 and information to which a party is entitled must be disclosed in time to permit his counsel

to make beneficial use thereof. Ark. R. Crim. P. 19.4 (2021).

Harness contends that, unlike the prosecutor, the victim witness coordinator does

not have an obligation to report exculpatory statements that would benefit the defendant in

either negating his guilt or reducing his punishment. Ark. R. Crim. P. 17.1(d). He argues

that the prosecutor set up a filtration system for victim witness statements by having the

coordinator speak to the witness and “relay only the information they see fit.” He maintains

that this system creates a legal barrier to the defendant’s having a fair trial and receiving due

process by being made aware of all statements that could potentially benefit him. He claims

that the coordinator’s interview on the prosecutor’s behalf should be considered a discovery

violation that undermines the confidence in the outcome of the trial.

We hold that the circuit court did not abuse its discretion by denying the mistrial

motion. The State emphasizes that the victim was allowed to be in the courtroom during

the entire trial, including during opening statements. Ark. R. Evid. 616 (2021) (the victim

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Shawn Harness v. State of Arkansas
2022 Ark. App. 360 (Court of Appeals of Arkansas, 2022)

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