Supreme Court of Arkansas

Emmitt Riley v. State of Arkansas

March 5, 20202020 Ark. 99

Summary

The court affirmed Riley’s convictions and life sentence and granted appointed counsel’s motion to withdraw after independently reviewing the record under the no-merit appeal procedure. It held that Riley’s sufficiency challenge was unpreserved because trial counsel made no directed-verdict motion, and it found no reversible error in the remaining adverse rulings because any error was harmless. A dissent argued that the appeal was not wholly frivolous because the exclusion of evidence concerning the victim’s violent character and the unraised sufficiency issue warranted adversarial briefing.