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 showed he entered the victim's home without privilege, 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 also held that Holly knowingly and intelligently waived his previously invoked right to counsel after initiating further contact with police, and that his wife was not acting as a police agent. Justice Wood, concurring, expressed concern that the record did not adequately develop Holly's competency and counsel's handling of competency issues.