Summary
The Arkansas Supreme Court reviewed Chris Aaron Schnarr’s manslaughter conviction arising from the shooting death of Arista Aldridge. The court held that evidence of the victim’s unknown prior violent conduct was properly excluded, but that excluding Schnarr’s family members from the courtroom during voir dire violated his constitutional right to a public trial. The court affirmed in part and reversed and remanded in part for a new trial.
Topics
Practice areas
Questions Presented
- Whether the circuit court improperly excluded specific instances of the victim's prior violent conduct that were unknown to Schnarr.
- Whether exclusion of Schnarr's family members from the courtroom during voir dire violated his constitutional right to a public trial and required a mistrial or new trial.
- Whether the circuit court erred by refusing to instruct the jury on negligent homicide.
- Whether the circuit court erred by refusing to instruct the jury on imperfect self-defense.
Holdings
- The circuit court did not abuse its discretion by excluding evidence of the victim's prior violent conduct of which Schnarr had no knowledge. When such evidence is offered to show the defendant's state of mind and reasonable apprehension of danger, the defendant's prior knowledge of the victim's acts is a relevancy prerequisite.
- The exclusion of three members of Schnarr's family from the courtroom during nearly the entire voir-dire process constituted a nontrivial courtroom closure and violated Schnarr's constitutional right to a public trial. The violation required reversal and remand for a new trial.
- The circuit court did not abuse its discretion by refusing to instruct the jury on negligent homicide because Schnarr intentionally fired three shots at Aldridge from fairly close range, leaving no evidence that he was unaware that his conduct posed a risk of causing death.
- The circuit court did not abuse its discretion by refusing to give an imperfect-self-defense instruction because the evidence provided no rational basis to find that Schnarr recklessly or negligently believed deadly force was necessary. There was no evidence that Aldridge appeared armed or threatened Schnarr with bodily harm.
Key quotations
“In determining whether a courtroom closure is so de minimus or trivial that it does not abridge a defendant’s Sixth Amendment right to a public trial, courts apply various factors, which include the length of the closure; the significance of the proceedings that took place while the courtroom was closed; and the scope of the closure.” (2017 Ark. 10)
“Weighing these factors, we cannot conclude that the closure was trivial, and we hold that Schnarr was deprived of his constitutional right to a public trial.” (2017 Ark. 10)
Factual background
After a near collision, Chris Aaron Schnarr and Arista Aldridge exchanged profanities while driving. Aldridge followed Schnarr, stopped in front of him, exited his vehicle, approached Schnarr's vehicle, and poked Schnarr in the face. Schnarr testified that Aldridge moved toward him after Schnarr pointed a handgun and ordered him to leave, prompting Schnarr to fire three shots; Aldridge died from a gunshot wound. During voir dire, a bailiff excluded three members of Schnarr's family from the courtroom for approximately two hours and thirty-seven minutes, covering nearly the entire jury-selection process.
Procedural history
Schnarr was charged with first-degree murder. His first trial ended in a mistrial when the jury could not reach a verdict. At the second trial, the jury convicted him of manslaughter and imposed a ten-year sentence. The circuit court rejected evidence of the victim's unknown prior violent acts, denied motions based on exclusion of family members during voir dire, and refused negligent-homicide and imperfect-self-defense instructions. The Supreme Court affirmed in part but reversed and remanded for a new trial based on the violation of Schnarr's constitutional right to a public trial during voir dire.
Remand instructions
Reverse the manslaughter conviction and remand for a new trial because Schnarr's constitutional right to a public trial was violated during voir dire. The judgment was otherwise affirmed, including the rulings on character evidence and the requested jury instructions.