Tracy Davis v. State of Arkansas

2025 Ark. App. 419
CourtCourt of Appeals of Arkansas
DecidedSeptember 10, 2025
StatusPublished

This text of 2025 Ark. App. 419 (Tracy Davis 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
Tracy Davis v. State of Arkansas, 2025 Ark. App. 419 (Ark. Ct. App. 2025).

Opinion

Cite as 2025 Ark. App. 419 ARKANSAS COURT OF APPEALS DIVISION IV No. CR-24-639

TRACY DAVIS Opinion Delivered September 10, 2025

APPELLANT APPEAL FROM THE JEFFERSON COUNTY CIRCUIT COURT V. [NO. 35CR-21-18]

STATE OF ARKANSAS HONORABLE ALEX GUYNN, JUDGE APPELLEE AFFIRMED

CINDY GRACE THYER, Judge

Appellant Tracy Davis appeals his Jefferson County Circuit Court conviction of one

count of fleeing in a vehicle—a Class D felony.1 In support of his claim for reversal, he argues

that there is insufficient evidence to support his conviction, that his right to a speedy trial

has been violated, and that the circuit court improperly admitted evidence of a prior

conviction during the guilt phase of trial. After reviewing the record and the arguments on

appeal, we find no error and affirm.

1 The information and the sentencing order state that he was charged with “fleeing in a vehicle causing damage.” The “causing damage” language, however, is superfluous for the Class D felony-fleeing statute in effect at that time. Ark. Code. Ann. § 5-54-125(d)(2) (Supp. 2019). I. Factual and Procedural History

At approximately 9:00 p.m. on November 12, 2020, a white four-door Hyundai

Electra ran a stop sign, almost striking another vehicle and forcing it off the road. Lieutenant

Jason Howard observed the incident and began pursuit of the Hyundai, which sped off at a

high rate of speed and without headlights. When Howard activated his lights, the Hyundai

pulled over before taking off again at a high rate of speed. Howard then activated his sirens

and engaged in a pursuit, which other officers eventually joined.

During the pursuit, the Hyundai ran several stop lights and at least six stop signs,

including two at busy intersections. It reached speeds between sixty and seventy miles an

hour, despite a thirty-mile-an-hour posted speed limit. Several of the streets traveled were

narrow streets in a residential area. While there was not much traffic at the time, at least two

of the intersections were located on well-traveled roads where there is frequently heavy traffic.

At one point during the chase, the Hyundai almost collided with a Jefferson County Sheriff’s

vehicle. The pursuit ended shortly thereafter when the Hyundai lost control, slid into a ditch,

and struck a culvert.

The driver (Davis) and his passenger (Nia Bullard) exited the vehicle and fled on foot.

Officers gave chase and were able to apprehend them. When officers searched the vehicle,

they found Davis’s identification. They also determined that the Hyundai had been reported

stolen.

On January 13, 2021, the State filed an information charging Davis with felony

fleeing in a vehicle and theft by receiving property valued at over $5,000 but less than

2 $25,000. The information was later amended: the theft-by-receiving charge was reduced to

theft by receiving property valued at over $1,000 but less than $5,000. The fleeing charge

was unaffected by the amendment.

During his February 1 plea and arraignment hearing, the court advised Davis of the

charges brought against him and inquired about his ability to retain counsel. Following

Davis’s response, the court appointed counsel and informed him that his trial was being set

for May 10 with an omnibus hearing on April 1. Davis, however, did not appear at the April

1 omnibus hearing, and an alias warrant was issued for his arrest.

On April 15, 2021, counsel moved to set aside the alias warrant. Counsel stated that

Davis had been in frequent contact with his bondsman but was unaware he was to appear at

the April 1 hearing. Counsel claimed that Davis later contacted him to inquire about any

upcoming court dates and discovered his failure-to-appear warrant. Counsel asserted that

Davis had not intentionally failed to appear and had no apparent history of such failures.

The State responded that Davis had been informed of the hearing date at his plea and

arraignment on February 1 and had provided no explanation for his failure to appear.

In January 2022, Davis incurred new charges after he was found with controlled

substances during the execution of a search warrant. He apparently was placed in handcuffs

and briefly detained but was ultimately released at the scene. Despite being detained by the

police, the alias warrant was not served on him at that time; instead, service on the warrant

was not effectuated until May 26, 2022. He appeared before the court for his first appearance

on the new charges and the alias warrant the next day.

3 Davis next appeared before the court for arraignment on July 11, 2022. The court set

an omnibus hearing for November 3, 2022, and set trial for January 23, 2023, on both the

old (35CR-21-18) and new charges (35CR-22-160). Speedy trial was not discussed at this

hearing, but the scheduling order entered thereafter stated that the period between April 1,

2021, and May 25, 2022, would be excluded for speedy-trial purposes in 35CR-21-18.

An omnibus hearing was held on November 8.2 The discussion at that hearing

revolved around a pending suppression motion in 35CR22-160 and the status of discovery.

Other than that, both parties announced they were ready for trial. The court then set an

issue-status hearing for January 5, 2023.3

At the issue-status hearing, the parties discussed the outstanding motion to set aside

the alias warrant; there was no discussion of speedy trial. However, on January 19, Davis,

through counsel, filed a motion to dismiss based on an alleged speedy-trial violation. He

claimed that the right to speedy trial attached at the time of his arrest on November 12,

2020; that his trial was set for January 23, 2023; and that, even taking into account any

defense continuances and the delay resulting from his failure to appear on April 1, 2021,

speedy trial had run. Accordingly, he claimed his case should be dismissed with prejudice.

2 The omnibus hearing was held on November 8, not November 3. It is unclear from the record why this date differed from the date on which it was previously set. 3 The issue-status hearing was held on January 10, not January 5. Once again, it is unclear from the record why this date differed from the date on which it was previously set.

4 The case was called for trial on January 23. The State informed the court that it had

recently been served with motions to dismiss based on speedy-trial violations in both 35CR-

21-18 and 35CR-22-160 and needed ten days to respond. The court then asked whether

Davis was detained, and his counsel responded that he was. When the court told the parties

that it intended to proceed with trial, the State informed the court that the chemist from the

crime lab was unavailable for trial.4 As a result, the court continued both cases and tolled

speedy trial due to the witness’s unavailability. Trial was reset for February 3.

Davis filed a continuance motion on February 2 because of inclement weather. The

court granted the motion and reset trial for May 10, with a speedy-trial and issue-status

hearing set for March 8.

Davis’s speedy-trial motions were briefly addressed at the March 8 status hearing.

However, the court continued the hearing to April 5 without ruling on the motions because

one of the officers involved in the January 2022 incident was injured and was unavailable to

testify.

The speedy-trial hearing was continued multiple times on defense motion and was

eventually held on November 2, 2023.

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2025 Ark. App. 419, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tracy-davis-v-state-of-arkansas-arkctapp-2025.