Parnell R. May v. State of Arkansas

Summary

The Arkansas Supreme Court affirmed Parnell R. May’s conviction for capital murder and life sentence. The court held that substantial evidence supported the conviction, including medical-examiner testimony that the victim died from blunt-force injuries inflicted during the assault. It also upheld the exclusion of emergency-room records and a death-certificate document and found May’s challenge to the medical examiner’s testimony unpreserved.

Holdings

1. Substantial evidence supported May's capital-murder conviction because the evidence permitted the jury to find that May's premeditated and deliberated beating caused Morales's death.
2. The circuit court did not abuse its discretion by excluding Morales's emergency-room medical records because May failed to establish the business-records foundation required by Arkansas Rule of Evidence 803(6), and he did not satisfy the statutory affidavit procedure.
3. The circuit court did not abuse its discretion by excluding the document offered as Morales's death certificate because it was neither generated by the medical examiner nor an official copy of the death certificate.
4. May's challenge that Dr. Erickson's testimony was invalid or fraudulent was not preserved because May failed to make a contemporaneous objection at trial.

Questions Presented

1. Whether substantial evidence supported May's capital-murder conviction, including proof that his beating caused Morales's death.
2. Whether the circuit court abused its discretion by excluding Morales's emergency-room medical records under Arkansas Rule of Evidence 803(6).
3. Whether the circuit court abused its discretion by excluding a purported death certificate under Arkansas Code Annotated section 12-12-313.
4. Whether May's challenge to the deputy chief medical examiner's testimony was preserved for appellate review.
5. Whether the record contained prejudicial error requiring reversal under Arkansas Supreme Court Rule 4-3(a).

Disposition

affirmed