Cases | Springs v. State, 244 S.W.3d 683 (Ark. 2006) | 2018
The defendant was convicted of one count of capital murder and two counts of aggravated assault. He appealed, arguing, among other things, that the trial court abused its discretion in admitting victim-impact evidence during his sentencing. Specifically, he argued that the evidence was irrelevant and inadmissible because it was not an aggravated circumstance that could be used to determine the punishment for capital murder. The Supreme Court of Arkansas affirmed, noting that it has repeatedly held that victim-impact evidence is admissible. The Court opined that, contrary to the defendant’s assertion, victim-impact evidence is not an additional aggravating circumstance and does not violate the statutory weighing process set out in Ark. Code Ann. §§ 5-4-603-605. It is “relevant evidence which informs the jury of the toll the murder has taken on the victim’s family.” If “excessive” victim-impact evidence is found to be so unduly prejudicial that it renders the trial fundamentally unfair, the Due Process Clause is the appropriate mechanism for relief. In this case, the testimony of the victim’s father, two sisters, and one of her children was relevant to show the impact that her death had on her family. Since it was not unduly prejudicial, the trial court did not abuse its discretion in admitting the evidence during the defendant’s sentencing.