GOEHLER v. STATE OF ARKANSAS (Majority)
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In this case heard by the Supreme Court of Arkansas, Jacoby Goehler was convicted by a jury for the first-degree murder of Davidlee Stansbury and sentenced to life in prison plus fifteen years. Goehler appealed his conviction on several grounds including the admission of incriminating statements made in police custody without his attorney present, denial of his motion to change venue, admission of testimony from his wife, and admission of a photograph of the victim. He also disputed the court's refusal to provide jury instructions on lesser-included offenses of manslaughter and second-degree murder.
The Supreme Court of Arkansas affirmed the lower court's decision on each point. The Court stated that Goehler failed to preserve his argument about his incriminating statements for appeal. It held that the trial court did not abuse its discretion in denying a change of venue because the court was able to select an impartial jury. It also found that the spousal privilege did not apply to the testimony of Goehler's wife because the facts she testified about were not privileged. The Court ruled that the admission of the photograph of the victim was not an abuse of discretion because it aided the jury in understanding the consequence of Goehler's actions. Lastly, the Court found no error in the trial court's refusal to provide jury instructions on manslaughter and second-degree murder because there was no rational basis for acquitting Goehler of first-degree murder and instead convicting him of the lesser offenses.
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