Supreme Court of Arkansas

Rodney Harmon v. State of Arkansas

May 28, 20202020 Ark. 217

Summary

The court affirmed Harmon’s convictions and forty-year aggregate sentence, holding that the State had no discovery obligation to obtain video footage held by private filmmakers, that denial of a further continuance and exclusion of related testimony were within the trial court’s discretion, and that admission of the penalty-phase recording was proper. Although the trafficking instruction was erroneous because it added purpose-to-deliver factors omitted from the model instruction, the error was harmless because another instruction accurately supplied those factors. The court also vacated the court of appeals’ opinion.