William Hoover v. State of Arkansas

2026 Ark. App. 67
CourtCourt of Appeals of Arkansas
DecidedFebruary 4, 2026
StatusPublished

This text of 2026 Ark. App. 67 (William Hoover 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
William Hoover v. State of Arkansas, 2026 Ark. App. 67 (Ark. Ct. App. 2026).

Opinion

Cite as 2026 Ark. App. 67 ARKANSAS COURT OF APPEALS DIVISION I No. CR-25-157

WILLIAM HOOVER Opinion Delivered February 4, 2026

APPELLANT APPEAL FROM THE FAULKNER COUNTY CIRCUIT COURT V. [NO. 23CR-22-133]

STATE OF ARKANSAS HONORABLE TROY B. BRASWELL, APPELLEE JR., JUDGE

AFFIRMED

STEPHANIE POTTER BARRETT, Judge

William Hoover filed this pro se appeal challenging his conviction by a Faulkner

County jury of possession of methamphetamine and his sentence of sixty months in the

Arkansas Division of Correction. Hoover presents five points on appeal for this court’s

consideration: the circuit court erred (1) in denying his suppression motion; (2) in not

appointing him a different public defender; (3) in denying his motion for a mistrial; (4) in

allowing an amendment to his charges two days prior to trial; and (5) in not dismissing his

case for lack of speedy trial. We find no error and affirm.

I. Relevant Facts

On February 4, 2022, Arkansas State Police Trooper Corey Earls initiated a traffic

stop of Hoover after observing that the vehicle he was operating displayed fictitious license

plates. During the stop, Trooper Earls discovered that Hoover’s driver’s license had been suspended for nearly twenty years and that the vehicle was not insured or registered. Because

Hoover was unable to lawfully operate the vehicle, Trooper Earls decided to have it towed.

Anticipating that an inventory search would be required before towing, Hoover was briefly

detained. Trooper Earls offered to retrieve Hoover’s cell phone so Hoover could arrange for

someone to pick him up. Hoover declined, stating he did not want Trooper Earls inside the

vehicle because he did not know what was inside it. During the inventory search, Trooper

Earls opened the driver’s door and observed, in plain view on the passenger-side floorboard,

a clear plastic bag containing a white substance he suspected was methamphetamine.

Subsequent testing confirmed the substance was methamphetamine weighing approximately

thirty-four grams. Trooper Earls then placed Hoover under arrest.

On February 11, 2022, the State filed its original felony information charging Hoover

with possession of at least two but less than ten grams of methamphetamine. At a hearing

on May 16, the State moved for a continuance because the Arkansas State Crime Laboratory

had not yet completed its analysis of the suspected methamphetamine. On August 8, the

State filed an amended information maintaining the same possession charge. Following the

filing of the amended information, Hoover—then represented by counsel—agreed to multiple

continuances, with time tolled.

A pretrial hearing was held on April 15, 2024. At that time, Hoover was represented

by public defender Brittani Burnette. Burnette informed the court that she and Hoover had

reached an impasse regarding her representation and that Hoover wished to proceed pro se.

Hoover asserted that Burnette had failed to do what he requested and asked that a different

2 public defender be appointed. The circuit court informed Hoover that it would not appoint

substitute counsel. Hoover then stated that he would represent himself. After providing

Hoover with a waiver-of-counsel form and conducting a colloquy, the court found that

Hoover knowingly and intelligently waived his right to counsel.

On May 10, 2024, Hoover filed a motion to suppress physical evidence and

statements. A hearing was held on Hoover’s motion on October 31. Representing himself,

Hoover argued that he did not understand why the State had been permitted to amend the

felony information. The State explained that the original information alleged an incorrect

quantity of methamphetamine. The State further stated that, although the first amended

information continued to allege possession of at least two but less than ten grams, it intended

to proceed on an allegation that Hoover possessed at least ten but less than two hundred

grams of methamphetamine. Hoover indicated he understood the explanation and did not

object to or move to quash the amended information.

On November 4, 2024, the State filed a second amended information charging

Hoover with possession of at least ten but less than two hundred grams of

methamphetamine. Hoover again did not object or move to quash the amended

information. At the outset of the jury trial on December 4, Hoover again expressed confusion

regarding the amended information. The circuit court reiterated the explanation previously

provided. Hoover acknowledged his understanding and did not move to dismiss or otherwise

challenge the amended information.

3 The State began its case-in-chief with testimony from Trooper Earls, who established

the facts leading up to Hoover’s arrest as set forth above. The State next called Sammy

Williams, deputy director of the Arkansas State Crime Laboratory. Williams testified he had

served as deputy director for approximately one year and had spent the preceding eighteen

years working as a forensic chemist. The State moved to qualify Williams as an expert in

forensic chemistry and narcotics analysis, which the circuit court granted.

Williams testified he received evidence from Trooper Earls in 2022 in connection

with this case. He identified the evidence as State’s exhibit 3 and testified that his analysis

determined the substance contained methamphetamine and dimethyl sulfone. Williams

further explained the procedures used to receive, document, and test the evidence. The State

moved to admit State’s exhibit 3 into evidence, and the circuit court granted the motion

without objection. The State rested at the conclusion of Williams’s testimony. Hoover did

not move for a directed verdict and did not call any witnesses in his defense.

During the sentencing phase of the trial, Hoover called his son-in-law, Joshua Nichols,

to testify on his behalf. Nichols had not been previously disclosed as a witness. Nichols

testified he believes Hoover is a good grandfather and that he had never seen Hoover using

drugs. After the jury retired to deliberate on sentencing, the circuit court announced that

one of the jurors had informed the bailiff that she previously knew Nichols. The juror stated

it had been a long time since she last saw him and felt she could proceed without issue.

Hoover moved for a mistrial, which the court denied. The circuit court explained that

4 Hoover had been asked at the beginning of trial to disclose his witnesses and had stated that

he had none.

This appeal followed.

II. Motion to Suppress

When reviewing a circuit court’s denial of a motion to suppress evidence, we conduct

a de novo review based on the totality of the circumstances, reviewing findings of historical

facts for clear error and determining whether those facts give rise to reasonable suspicion or

probable cause, giving due weight to the inferences drawn by the circuit court. Cagle v. State,

2019 Ark. App. 69, 571 S.W.3d 47. A finding is clearly erroneous when, even if 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. Id. We defer to the circuit court’s

superior position in determining the credibility of the witnesses and resolving any conflicts

in the testimony. Id.

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

Related

Wooten v. State
91 S.W.3d 63 (Supreme Court of Arkansas, 2002)
Armstrong v. State
233 S.W.3d 627 (Supreme Court of Arkansas, 2006)
Fricks v. State
2016 Ark. App. 415 (Court of Appeals of Arkansas, 2016)
Lewis v. State
2017 Ark. App. 442 (Court of Appeals of Arkansas, 2017)
Cagle v. State
2019 Ark. App. 69 (Court of Appeals of Arkansas, 2019)
Tyler Chandler v. State of Arkansas
2025 Ark. App. 566 (Court of Appeals of Arkansas, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
2026 Ark. App. 67, Counsel Stack Legal Research, https://law.counselstack.com/opinion/william-hoover-v-state-of-arkansas-arkctapp-2026.