Billy Allen Combs v. State of Arkansas

Summary

The court affirmed Combs's capital-murder conviction after concluding that the State rebutted the presumption of prejudice arising from the trial court's failure to bring the jury into open court after it asked to see a police statement. Although the statutory procedure was mandatory and was violated, the entire communication was preserved in the record, counsel had an opportunity to object, and the trial court did not provide evidence, answer the evidentiary question, or instruct the jury on law.