On September 17, 2015, the Supreme Court of Arkansas upheld the conviction of Arkansas state prisoner Robert T. Holland who was convicted of capital murder for strangling his cellmate and sentenced to death. Holland's appeal alleged the trial court should have upheld his Batson challenge to the prosecutor's use of peremptory strikes to exclude three blacks from the jury.
Holland was serving a life sentence for capital murder at the Cummins Unit. He had been disciplined multiple times for refusing to accept a cellmate. He finally agreed to accept a cellmate and Matthew Scheile, who was serving a four-year sentence, was placed in his cell. He murdered Scheile later the same night and reported the crime to guards. Holland told a state investigator he had murdered Scheile because it would force prison officials to. assign him to a single cell without subjecting him to continuous disciplinary sanctions.
The prosecutor used three peremptory strikes to exclude blacks from the jury. Holland objected. Finding a prima facie case for discrimination, the trial court allowed the prosecutor to explain the strikes. The prosecutor offered race-neutral reasons for the strikes and Holland did not renew the objection, but raised the issue later on appeal.
Assisted by attorneys Charlene Davidson Henry and Paul J. Teufel, Holland argued the reasons were insufficiently race-neutral. The Supreme'Court held that the trial court's decision allowing the strikes was not clearly against the preponderance of the evidence as the prosecutor's reasons for the strikes were sufficiently race-neutral. Holland raised two other grounds, but they were not properly preserved for appeal. The conviction was upheld. See: Holland v. State, 2015 Ark. 318.
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Related legal case
Holland v. State
|2015 Ark. 318
|State Supreme Court