Travis Price v. State of Arkansas

2023 Ark. 36, 660 S.W.3d 316
CourtSupreme Court of Arkansas
DecidedMarch 9, 2023
StatusPublished
Cited by2 cases

This text of 2023 Ark. 36 (Travis Price v. State of Arkansas) is published on Counsel Stack Legal Research, covering Supreme Court of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Travis Price v. State of Arkansas, 2023 Ark. 36, 660 S.W.3d 316 (Ark. 2023).

Opinion

Cite as 2023 Ark. 36 SUPREME COURT OF ARKANSAS No. CR-22-496

Opinion Delivered: March 9, 2023 TRAVIS PRICE APPELLANT PRO SE APPEAL FROM THE JEFFERSON COUNTY CIRCUIT V. COURT [NO. 35CR-16-253]

STATE OF ARKANSAS HONORABLE JODI RAINES DENNIS, APPELLEE JUDGE

AFFIRMED.

ROBIN F. WYNNE, Associate Justice

Travis Price appeals the trial court’s denial and dismissal of his petition for

postconviction relief filed pursuant to Rule 37.1 of the Arkansas Rules of Criminal

Procedure (2021). On appeal, Price contends that he is entitled to postconviction relief

because trial counsel was ineffective for failing to investigate his case or interview witnesses,

for failing to address and provide proof regarding his federal-parole status during his

suppression hearing, and for failing to investigate mitigation evidence for sentencing.

Because Price has not demonstrated entitlement to Rule 37.1 postconviction relief, we affirm

the trial court’s denial and dismissal of the petition.

A Jefferson County jury convicted Price of first-degree felony murder, two counts of

aggravated robbery, and a felon-in-possession-of-a-firearm enhancement. Price was sentenced as a habitual offender to an aggregate term of life imprisonment. We affirmed. Price v. State,

2019 Ark. 323, 588 S.W.3d 1.

We will not reverse the trial court’s ruling on a petition for postconviction relief

under Rule 37.1 unless it is clearly erroneous. Sirkaneo v. State, 2022 Ark. 124, 644 S.W.3d

392. 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 made. Williams v. State, 2019 Ark. 129, 571 S.W.3d 921.

Our standard for ineffective-assistance-of-counsel claims is the two-prong analysis set

forth in Strickland v. Washington, 466 U.S. 668 (1984). Reynolds v. State, 2020 Ark. 174, 599

S.W.3d 120. Under the Strickland standard, to prevail on a claim of ineffective assistance of

counsel, the petitioner must show that (1) counsel’s performance was deficient and (2) the

deficient performance prejudiced his defense. Id. Unless a petitioner makes both showings,

the allegations do not meet the benchmark on review for granting relief on a claim of

ineffective assistance. Id. To demonstrate prejudice, 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. Id. A reasonable probability is a probability sufficient to

undermine confidence in the outcome of the trial. Id.

On appeal, Price contends that trial counsel was ineffective. Specifically, Price argues

that trial counsel failed to investigate pretrial issues such as contacting and interviewing a

critical eyewitness, Angela Davis; and that he failed to produce documentation that Price

was under federal supervision at the time of his arrest, which was an issue that “grew to epic

2 proportions beyond prejudicial during Price’s [ ] motion to suppress statement hearing.” He

further argues that trial counsel failed to investigate mitigation, interview potential witnesses,

and prepare an adequate defense for the sentencing phase, particularly when he requested

that counsel interview a witness, Galvester Walker, a close relative. Notably, Price’s Rule 37.1

petition made general claims that trial counsel was ineffective for failing to conduct any

independent investigation of the facts and circumstances of Price’s case, interview any

potential witnesses, or conduct an adequate investigation of mitigation to present in the

sentencing phase. Price did file a “second amended petition” for postconviction relief; 1

however, the trial court found that Price failed to petition for leave to amend, and it did not

make any findings on the merits of the amended petition,2 such that the court’s order

1 In his second amended petition, Price argued that trial counsel failed to independently investigate his case and that trial counsel failed to investigate mitigation evidence for sentencing, including interviewing Walker and other character witnesses. Price raised additional grounds: trial counsel was ineffective during a suppression hearing by failing to follow through with objections by bringing out supporting documentation of Price’s federal-parole status; trial counsel was ineffective for failing to state claims that required suppression of his pretrial statements; his convictions were obtained in violation of due process and double jeopardy; and his convictions violated the Sixth and Fourteenth Amendments. 2 Our rules of criminal procedure do allow for the amendment of a Rule 37 petition, but only with leave of the court. Ark. R. Crim. P. 37.2(e). The record does not reflect that Price sought leave to amend, nor does he challenge the issue on appeal.

3 dismissing and denying relief was limited to the grounds filed in the original Rule 37.1

petition.3

Price’s argument regarding trial counsel’s failure to conduct a pretrial investigation—

specifically, his failure to interview Angela Davis—is an argument greatly expanded on appeal.

An appellant is limited to the scope and nature of the claims raised below in a Rule 37.1

proceeding and cannot raise new arguments on appeal. Elliot v. State, 2022 Ark. 165, 653

S.W.3d 776. In the same vein, Price’s contention regarding trial counsel’s failure to produce

documentation that he was under federal supervision at the time of his arrest is being raised

for the first time on appeal and will not be addressed. See Winkle v. State, 2016 Ark. 98, at

14–15, 486 S.W.3d 778, 788 (holding that an argument was not preserved for appellate

review and this court was precluded from review on appeal where the trial court had not

provided a ruling on the argument).

Under Rule 37.1, Price’s assertion that his trial counsel was ineffective for failing to

conduct an adequate pretrial investigation, must delineate the actual prejudice that arose

from the failure to investigate and demonstrate a reasonable probability that the specific

material that would have been uncovered without further investigation could have changed

the outcome of the trial. Gordon v. State, 2018 Ark. 73, 539 S.W.3d 586. Neither conclusory

3 Although the State argues that Price’s failure to challenge the trial court’s finding that the “form of the petition fails to comply with Rule 37.1(b) and is subject to dismissal[]” is fatal to his appeal, the trial court did proceed to address the merits of the petition in its order denying the petition and dismissing it with prejudice. See Barrow v. State, 2012 Ark. 197 (Rule 37.1(b) does not deprive a court of authority to rule on the merits of a petition if it elects to do so.).

4 statements nor allegations without factual substantiation are sufficient to overcome the

presumption that counsel’s representation was effective under the Strickland standard and

cannot provide a basis for postconviction relief. Id. General assertions that counsel did not

aggressively prepare for trial are not sufficient to establish a claim of ineffective assistance of

counsel. Wertz v. State, 2014 Ark. 240, 434 S.W.3d 895.

Notwithstanding the claims that cannot be addressed on appeal, Price generally

claims that counsel refused to interview potential witnesses after he asked counsel to do so

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