State of Arkansas, Appellant v. Shawn Trevell Rainer, Appellee

Summary

The Supreme Court of Arkansas reversed the grant of Rule 37 postconviction relief and the resulting new-trial order. It held that the victim's prior acts of knife violence were not relevant to Rainer's accident defense, counsel was not ineffective for failing to renew the motion-in-limine objection, and the unrecorded pretrial hearing did not render the conviction void or establish prejudice. The court did not reach Rainer's separate claim concerning his offender designation because the circuit court had ruled that issue moot. Justice Hart, joined by the Chief Justice and Justice Baker, dissented, arguing that the circuit court properly found ineffective assistance based on counsel's failure to renew the objection after the State's case.