Rickey Howard, Jr. v. State of Arkansas

Summary

The Arkansas Court of Appeals affirmed Rickey Howard Jr.'s convictions for first-degree murder, aggravated robbery, committing terrorist acts, and firearm enhancements. The court held that evidence independent of accomplice testimony sufficiently corroborated Howard's connection to the crimes, including a cell-phone video, his statements, associations, and flight. The court also held that Howard failed to preserve his challenge to the video's authentication because he did not raise that specific objection at trial.

Holdings

1. The evidence sufficiently corroborated the accomplice testimony because, even excluding statements attributed to accomplices, Howard's own statements, the cell-phone video, evidence of his association with the participants, and his flight tended in some degree to connect him with the crimes.
2. The authentication challenge was not preserved for appellate review because Howard did not make a specific authentication objection in the circuit court and could not change the grounds of his objection on appeal.

Questions Presented

1. Whether evidence independent of accomplice testimony sufficiently tended to connect Howard to the crimes to corroborate that testimony.
2. Whether the appellate court could consider Howard's challenge to authentication of the cell-phone video when he did not make a specific authentication objection at trial.

Disposition

affirmed