Supreme Court of Arkansas
Erickson Dimas-Martinez v. State of Arkansas
December 8, 20112011 Ark. LEXIS 593
Summary
The court reversed the convictions and sentences and remanded for a new trial because one juror slept through part of the evidence and another repeatedly violated instructions against tweeting about the case, constituting juror misconduct and an abuse of discretion. The court also held that a substantial-evidence standard, rather than a slight-evidence standard, governs whether an aggravating circumstance may be submitted to a capital-sentencing jury, while rejecting the remaining evidentiary and mental-evaluation challenges. The court did not reach the challenge concerning references to automatic appellate review.