Ingram v. State

Summary

The Arkansas Supreme Court affirmed Richard Ingram’s capital-murder conviction and life-without-parole sentence. The court held that the trial court did not abuse its discretion by removing a juror who had spoken with potential witnesses and seating an alternate, and it rejected Ingram’s claim that the removal constituted structural error.

Holdings

1. The circuit court did not abuse its discretion in removing the juror and seating an alternate because the court had a reasonable basis to be concerned that the juror violated its instruction against speaking with potential witnesses and because the accounts of the interaction varied.
2. An appellant challenging the removal of a juror and seating of an alternate must demonstrate prejudice.
3. The court would not consider Ingram's structural-error argument because he did not raise that argument below.
4. The court declined to apply a presumption of prejudice or automatic-reversal rule to the juror-removal issue because the case did not involve the use of a suspect classification such as race in jury selection.

Questions Presented

1. Whether the circuit court abused its discretion by removing a juror and seating an alternate juror.
2. Whether the juror's removal constituted structural error requiring automatic reversal without a showing of prejudice.
3. Whether the Arkansas Supreme Court should consider the structural-error argument when it was not raised below.

Disposition

affirmed