Montrell Simmons v. State of Arkansas

Summary

The court affirmed Simmons's convictions for aggravated robbery and capital murder because he failed to preserve his challenge to the sufficiency of the evidence supporting aggravated robbery. His directed-verdict motion addressed only the similarity between capital murder and first-degree murder and did not identify any deficient element of aggravated robbery. Because the sufficiency argument was unpreserved, the court also declined to address whether the capital-murder conviction could be reduced to first-degree murder.