Supreme Court of Arkansas

Zachary Holly, Appellant v. State of Arkansas, Appellee

June 1, 20172017 Ark. LEXIS 165

Summary

The court affirmed Holly’s convictions and sentences, holding that substantial evidence supported the residential-burglary conviction, that his conditional offer to plead guilty was not relevant mitigating evidence of acceptance of responsibility, and that his custodial confession was voluntary. The court concluded that Holly reinitiated contact after invoking counsel, knowingly waived his rights, and was not coerced through his wife’s involvement. Justice Wood, concurring, expressed concern about the incomplete development of Holly’s competency and counsel-adequacy issues and hoped they would be addressed in later postconviction proceedings.