Thomas Wilcoxon v. State of Arkansas

2025 Ark. App. 466
CourtCourt of Appeals of Arkansas
DecidedOctober 1, 2025
StatusPublished

This text of 2025 Ark. App. 466 (Thomas Wilcoxon 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
Thomas Wilcoxon v. State of Arkansas, 2025 Ark. App. 466 (Ark. Ct. App. 2025).

Opinion

Cite as 2025 Ark. App. 466 ARKANSAS COURT OF APPEALS DIVISION I No. CR-24-715

Opinion Delivered October 1, 2025 THOMAS WILCOXON APPEAL FROM THE ASHLEY COUNTY APPELLANT CIRCUIT COURT [NO. 02CR-20-63] V. HONORABLE CREWS PURYEAR, JUDGE STATE OF ARKANSAS AFFIRMED APPELLEE

WAYMOND M. BROWN, Judge

On March 6, 2020, appellant Thomas Wilcoxon was charged by felony information with one

count of internet stalking of a child in violation of Arkansas Code Annotated section 5-27-306.1 On

May 17, 2021, the State amended the information to charge Wilcoxon as a habitual offender2 with

one count of attempted internet stalking of a child3 and one count of pandering.4 The charges arose

from communications between Wilcoxon and a fictitious Facebook account belonging to “Julie

1 (Supp. 2019).

2In 2005, Wilcoxon pleaded guilty to the charges of rape and introduction of a controlled substance into the body of another person.

3 Ark. Code Ann. § 5-3-201(a)(2) (Repl. 2013). 4 Ark. Code Ann. § 5-27-304(a)(2) (Repl. 2013). Williams.” The account was established to aid with investigations into both narcotics trafficking and

sex trafficking involving minors, and it was monitored by the Ashley County Sheriff’s Department.

Following an Ashley County Circuit Court jury trial, Wilcoxon was convicted of internet

stalking of a child and pandering. An aggregate sentence of thirty-five years’ incarceration was

imposed. We affirmed his convictions on direct appeal. 5 Wilcoxon then filed a petition for

postconviction relief pursuant to Arkansas Rule of Criminal Procedure 37.1. Without holding an

evidentiary hearing, the circuit court denied his petition seeking Rule 37.1 relief. Wilcoxon filed an

untimely notice of appeal; however, this court granted his pro se motion for belated appeal. Because

Wilcoxon has failed to demonstrate that he is entitled to postconviction relief, we affirm.

On appeal from a circuit court’s ruling on a petitioner’s request for Rule 37 relief, this court

will not reverse the circuit court’s decision granting or denying postconviction relief unless it is

clearly erroneous.6 A finding is clearly erroneous when, although there is evidence to support it, the

appellate court after reviewing the entire evidence is left with the definite and firm conviction that a

mistake has been committed.7

The benchmark for judging a claim of ineffective assistance of counsel is “whether counsel’s

conduct so undermined the proper functioning of the adversarial process that the trial cannot be

relied on as having produced a just result.”8 Pursuant to Strickland, we assess the effectiveness of

5 See Wilcoxon v. State, 2022 Ark. App. 458, 655 S.W.3d 686. 6 Kemp v. State, 347 Ark. 52, 60 S.W.3d 404 (2001).

7 Id. 8 Strickland v. Washington, 466 U.S. 668, 686 (1984).

2 counsel under a two-prong standard. First, a petitioner raising a claim of ineffective assistance must

show that counsel made errors so serious that counsel was not functioning as the “counsel” guaranteed

the petitioner by the Sixth Amendment to the United States Constitution. 9 A petitioner making an

ineffective-assistance-of-counsel claim must show that counsel’s performance fell below an objective

standard of reasonableness.10 A court must indulge in a strong presumption that counsel’s conduct

falls within the wide range of reasonable professional assistance.11

Second, the petitioner must show that counsel’s deficient performance so prejudiced

petitioner’s defense that he or she was deprived of a fair trial.12 The petitioner must show there is a

reasonable probability that, but for counsel’s errors, the fact-finder would have had a reasonable

doubt respecting guilt, i.e., the decision reached would have been different absent the errors. 13 A

reasonable probability is a probability sufficient to undermine confidence in the outcome of the trial. 14

Unless a petitioner makes both showings, it cannot be said that the conviction resulted from a

9 Williams v. State, 369 Ark. 104, 108, 251 S.W.3d 290, 293 (2007). 10 Abernathy v. State, 2012 Ark. 59, 386 S.W.3d 477 (per curiam). 11 Id. 12 Id. 13 Howard v. State, 367 Ark. 18, 238 S.W.3d 24 (2006). 14 Id.

3 breakdown in the adversarial process that renders the result unreliable. 15 Additionally, conclusory

statements that counsel was ineffective cannot be the basis for postconviction relief.16

On appeal, Wilcoxon argues that the circuit court clearly erred in holding that he failed to

demonstrate sufficient facts to establish that counsel’s performance fell below an objective standard

of reasonableness.17 In arguing ineffective assistance of counsel, Wilcoxon argues that his trial counsel

was ineffective for (1) failing to preserve an argument of insufficient evidence to show a sexual

purpose for attempted internet stalking; and (2) failing to preserve an argument of insufficient

evidence to show knowledge of age for attempted internet stalking.

Arkansas Code Annotated section 5-27-306(a)(1) provides that a person who is twenty-one

years of age or older commits the offense of internet stalking of a child if the person knowingly uses

a computer online service, internet service, or local internet bulletin board service to seduce, solicit,

lure, or entice a child fifteen years of age or younger in an effort to arrange a meeting with the child

for the purpose of engaging in sexual intercourse, sexually explicit conduct, or deviate sexual activity.

If the person tries to arrange a meeting with an individual fifteen years of age or younger, it is a class

B felony, even if the meeting did not take place.18

Wilcoxon was convicted of attempted internet stalking of a child. Arkansas Code Annotated

section 5-3-201(a) provides that a person attempts to commit an offense if he or she purposely

15 Id. 16 Anderson v. State, 2011 Ark. 488, 385 S.W.3d 783.

17 Abernathy, 2012 Ark. 59, 386 S.W.3d 477. 18 Ark. Code Ann. § 5-27-306(b)(1) (Supp. 2021).

4 engages in conduct that would constitute an offense if the attendant circumstances were as the person

believes them to be, or constitutes a substantial step in a course of conduct intended to culminate in

the commission of an offense whether or not the attendant circumstances are as the person believes

them to be.

For his first point, Wilcoxon claims that, despite his request, trial counsel, in his directed-

verdict motion, failed to challenge the sufficiency of the evidence to show a sexual purpose for

attempted internet stalking. He asserts that the “argument was significant to his defense” and that,

absent the error, the fact-finder would have had a reasonable doubt respecting guilt. When a

petitioner asserts that counsel is ineffective for the failure to make a motion or an argument, the

petitioner must show that the motion or argument would have been meritorious because the failure

to make an argument that is meritless is not ineffective assistance of counsel. 19

In support of his assertion, Wilcoxon relies on the dissenting opinions from his direct appeal.

His argument is meritless for multiple reasons. First, dissenting opinions hold no precedential

value.20 Second, neither dissent focuses on the sexual-purpose element of the offense. Judge

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Kemp v. State
60 S.W.3d 404 (Supreme Court of Arkansas, 2001)
Williams v. State
251 S.W.3d 290 (Supreme Court of Arkansas, 2007)
Howard v. State
238 S.W.3d 24 (Supreme Court of Arkansas, 2006)
Jackson v. Smith Blair, Inc.
379 S.W.3d 555 (Court of Appeals of Arkansas, 2010)
Anderson v. State
2011 Ark. 488 (Supreme Court of Arkansas, 2011)
Abernathy v. State
2012 Ark. 59 (Supreme Court of Arkansas, 2012)
Thomas D. Wilcoxon v. State of Arkansas
2022 Ark. App. 458 (Court of Appeals of Arkansas, 2022)
Randy W. Duck v. State of Arkansas
2020 Ark. App. 161 (Court of Appeals of Arkansas, 2020)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ark. App. 466, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thomas-wilcoxon-v-state-of-arkansas-arkctapp-2025.