Scotty Ray Gardner v. State of Arkansas

Summary

The court affirmed Gardner’s capital-murder conviction and death sentence. It held that Gardner’s statements reflected frustration with appointed counsel rather than an unequivocal request for self-representation, that the model penalty instruction adequately conveyed the jury’s discretion, and that substantial evidence supported the pecuniary-gain and especially-cruel aggravators. The court declined to review Gardner’s unpreserved challenge to the depraved-manner instruction and found no reversible error in its required review of the record.