Sherrel Courvelle v. State of Arkansas

Summary

The Arkansas Court of Appeals affirmed Sherrel Courvelle’s three convictions for felony failure to appear and her consecutive fifteen-year sentences. The court held that substantial evidence supported the convictions because Courvelle failed to establish a reasonable excuse for not appearing at a scheduled disposition hearing. The court declined to consider her double-jeopardy challenge because it was not preserved in the circuit court.

Holdings

1. Substantial evidence supported Courvelle's three convictions because she was ordered to appear at a specified time and place, knew of the order, failed to appear, and did not establish to the jury's satisfaction that she had a reasonable excuse.
2. Courvelle's double-jeopardy argument was waived because she did not object on that ground in the circuit court after the jury returned the convictions.

Questions Presented

1. Whether substantial evidence supported Courvelle's three convictions for failure to appear when she claimed a reasonable excuse based on a family medical emergency.
2. Whether two of the three failure-to-appear convictions should be reversed and dismissed on double-jeopardy grounds because they arose from the same absence.
3. Whether the unpreserved double-jeopardy claim could be reviewed under the fourth Wicks exception.

Disposition

affirmed