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

Summary

The Supreme Court of Arkansas affirmed the denial of Adam Doty's Rule 37 petition alleging that trial counsel was ineffective in three respects: failing to obtain an undisclosed 911 recording, advising a defense witness not to volunteer certain testimony, and failing to introduce photographs and related evidence. The court held that counsel's conduct was within the range of reasonable professional assistance and therefore did not reach the prejudice prong of the ineffective-assistance test. Justice Hart concurred, agreeing that affirmance was required under existing Rule 37 jurisprudence but urging reconsideration of assigning postconviction proceedings to the trial judge and stating that the undisclosed recordings constituted a prosecutorial disclosure violation that could not support Rule 37 relief.