Tyler Edward Tait v. State of Arkansas

Summary

The Supreme Court of Arkansas affirmed Tyler Edward Tait’s conviction for second-degree murder arising from the strangulation death of Moria Kinsey. The court held that substantial evidence supported the conviction, that the circuit court properly instructed the jury on second-degree murder despite Tait’s claim of absolute innocence, and that the circuit court did not abuse its discretion in denying a new trial based on alleged juror misconduct. The court vacated the court of appeals’ opinion and clarified the application of the lesser-included-offense standard under Arkansas law.

Holdings

1. Substantial evidence supported Tait's conviction for second-degree murder. The jury was entitled to credit the State's medical-examiner testimony over the defense expert's contrary opinion and to resolve conflicts in the evidence.
2. A lesser-included-offense instruction is proper when the evidence provides a rational basis for acquitting the defendant of the charged offense and convicting him or her of the lesser offense; the analysis is case-specific and applies even when the defendant claims total innocence. The instruction is appropriate when supported by the slightest evidence.
3. The phrase "under circumstances manifesting extreme indifference to the value of human life" is not unconstitutionally vague, and second-degree murder is a lesser-included offense of purposeful first-degree murder.
4. The circuit court did not abuse its discretion in denying Tait's motion for a new trial because Tait failed to establish that juror misconduct occurred, and the circuit court's credibility determination favoring the juror who denied conducting outside research was not clearly erroneous.

Questions Presented

1. Whether substantial evidence supported Tait's second-degree-murder conviction.
2. Whether the circuit court properly instructed the jury on second-degree murder as a lesser-included offense despite Tait's claim of absolute innocence.
3. Whether the phrase "under circumstances manifesting extreme indifference to the value of human life" is unconstitutionally vague and whether second-degree murder is a lesser-included offense of purposeful first-degree murder.
4. Whether the circuit court erred in denying Tait's motion for a new trial based on alleged juror misconduct and extraneous information.

Disposition

other