Adam F. Doty, Appellant v. State of Arkansas, Appellee

Summary

The court affirmed the denial of Rule 37 postconviction relief, holding that Doty failed to establish deficient performance by trial counsel in connection with the missing 911 call, advice concerning a defense witness's testimony, or unused photographs. The court applied the clearly erroneous standard to the circuit court's findings and concluded that each challenged decision was either impossible for counsel to have prevented or supported by reasonable trial strategy, so it did not reach prejudice on any claim. Justice Hart concurred, agreeing that the case was affirmable but arguing that Rule 37 proceedings should generally be assigned to a judge other than the trial judge and that the undisclosed 911 recordings constituted a Brady violation potentially addressable through coram nobis.