Jose Rufino Garcia-Chicol v. State of Arkansas

Summary

The court affirmed the rape conviction and life sentence, holding that the bailiff's communication with the jury did not require a mistrial because the jury had already reached its verdict on the greater offense and individual polling established that the verdict was unanimous and uninfluenced by outside information. It also held that the translated Spanish letter was properly admitted despite the shortened notice, the translator's wording, and the lack of translator testimony. The translation was attributable to the appellant through the language-conduit principle and therefore did not implicate the Confrontation Clause.