Randle v. Arkansas (Per Curiam)Annotate this Case
Appellant Anthony Randle was found guilty by jury of capital murder in the death of Ranson Harrison, for which he was sentenced to life imprisonment without parole. Randle appealed, and his conviction and sentence was affirmed by the Supreme Court. Randle filed a timely petition under Arkansas Rule of Criminal Procedure 37.1 (2008); however, the petition was not verified. In October 2015, the trial court denied relief, and Randle appealed. The State petitioned that the appeal be dismissed, arguing that Randle’s Rule 37.1 petition was not verified, which required dismissal of the appeal pursuant to Rule 37.1(d). The State additionally argued that Randle’s claim on appeal arose out of a pleading he filed challenging the State’s response to his Rule 37.1 petition. Because he had not sought leave to amend, Randle’s responsive pleading could not be considered an amended Rule 37.1 petition. Consequently, the State contended that appellate review of the claim was precluded because it was raised for the first time on appeal. After review, the Arkansas Supreme Court agreed with the State’s claims regarding dismissal of Randle’s appeal.