Eric Z. Grillot v. State of Arkansas

Summary

The Supreme Court of Arkansas affirmed Eric Grillot's convictions for first-degree murder, aggravated robbery, theft of property, and hindering apprehension arising from Jeremy Phillips's shooting of William Jackson during a staged drug transaction. It held the sufficiency challenge to the first-degree murder conviction unpreserved because Grillot's directed-verdict motions addressed only capital murder without naming the lesser-included offense or apprising the trial court of its differing elements, found sufficient evidence of deprivation for the aggravated robbery and theft convictions, and upheld denial of the motion to suppress under a newly clarified totality-of-the-circumstances standard that disavows both the 'light most favorable to the State' and 'all doubts resolved in favor of individual rights' formulations. The court further sustained the trial court on the juror-misconduct claim (invited error), the burden-of-proof limitation in closing argument, any capital-murder-instruction error (harmless because the jury acquitted on that charge), and the first-degree-murder lesser-included instruction, which slight evidence of purposeful accomplice conduct supported. Justice Hannah, concurring in part and dissenting in part and joined by Justice Thornton, would have reached the sufficiency of the accomplice-liability evidence because its elements are identical for both homicide degrees, and argued the court has never decided whether the State may obtain a lesser-included instruction under Ark. Code Ann. § 5-1-110 over a defendant's objection.