Erica Rae Grube v. State of Arkansas

Summary

The court affirmed Grube’s negligent-homicide conviction without reaching the sufficiency of the evidence because she failed to preserve that challenge under the criminal procedure rule governing bench trials. Her counsel made a closing argument asserting reasonable doubt but never moved for dismissal at the close of all the evidence. The court strictly construed the preservation rule and held that the argument did not substitute for the required motion.