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

Summary

The court reversed the circuit court’s order granting postconviction relief and a new trial. It held that evidence of the victim’s specific prior acts of knife violence was not relevant to Rainer’s accident defense, so counsel was not ineffective for failing to renew the objection or pursue the issue on appeal; the failure to record the pretrial hearing also did not render the conviction void or establish prejudice. The court did not reach Rainer’s separate offender-designation claim because the circuit court had ruled it moot rather than deciding it. Justice Hart, joined by the Chief Justice and Justice Baker, dissented, asserting that the circuit court granted relief because counsel failed to renew the motion in limine after the trial context became clear.