Ramaker v. State

Summary

The Supreme Court of Arkansas affirmed Michael Ramaker’s conviction for first-degree murder and his thirty-five-year sentence. The court held that his sufficiency challenge was procedurally barred because he did not move for a directed verdict on the lesser-included offense, and it rejected or found harmless his challenges to the admission and repair of the shotgun, redaction of polygraph references, and admission of crime-scene photographs.

Holdings

1. Ramaker's sufficiency challenge was procedurally barred because his directed-verdict motions challenged only capital murder and did not address the lesser-included offense of first-degree murder for which he was convicted.
2. The challenge to admission of the shotgun was procedurally barred because Ramaker withdrew his chain-of-custody objection and stated that he had no objection to admission.
3. Any error in ordering the shotgun repaired was harmless because Ramaker could not demonstrate prejudice.
4. The trial court properly allowed Ramaker's custodial statement to be redacted to exclude references to his requests to take a polygraph examination.
5. The trial court did not abuse its discretion by admitting the photograph depicting the nature and location of the victim's wound while excluding a cumulative photograph.
6. Ramaker's claim that the trial court improperly commented on the evidence was procedurally barred because he made no contemporaneous objection or motion for mistrial when the court explained the repair to the jury.

Questions Presented

1. Whether the evidence was sufficient to support Ramaker's first-degree-murder conviction.
2. Whether the trial court erred in admitting the shotgun after the police had cleaned it and after it was repaired following a trial demonstration.
3. Whether the trial court erred by admitting a redacted custodial statement that omitted Ramaker's offers to take a polygraph examination.
4. Whether the trial court abused its discretion by admitting a gruesome photograph of the victim's wound.
5. Whether the trial court improperly commented on the evidence when explaining the shotgun's repair to the jury.

Disposition

affirmed