The Arkansas Supreme Court has affirmed the capital murder conviction of Reggie Matthews for the killing of Tiana Robinson, concluding that his arguments for reversal lacked merit. Matthews was sentenced to life in prison after a jury found him guilty of the 2023 murder, which occurred during a well-attended barbecue in Osceola, Arkansas.
The Supreme Court rejected four distinct challenges raised by Matthews, covering the sufficiency of the evidence, the admissibility of his post-arrest statements, a witness’s unsolicited comment during trial, and the application of the best-evidence rule.
A History of Abuse Culminates in Murder
The factual background painted a picture of an escalating and abusive relationship between Matthews and the victim, Tiana Robinson. Evidence presented at trial showed a pattern of threatening behavior leading up to the September 6, 2023, incident. This included prior police calls regarding disputes, an incident where Matthews refused to leave a party Robinson hosted, and a 911 call one month before the murder where Robinson—with Matthews present and armed—reported that he was threatening to kill her. Just two days before the killing, Matthews was spotted circling Robinson’s home, prompting her to call the police out of fear for her safety.
The murder itself took place at a public barbecue. Multiple eyewitnesses testified that Matthews arrived, spotted Robinson, chased her down as she tried to flee, and shot her five times in the back. Witnesses further stated that Matthews stood over her and taunted her as she lay dying.
Sufficiency of Evidence Challenge Rejected
Matthews first argued that the evidence presented was insufficient to support his conviction, specifically challenging whether the State proved premeditation and deliberation.
The Supreme Court reviewed the evidence in the light most favorable to the jury’s verdict. Justice Nicholas J. Bronni, writing for the majority, noted that premeditation and deliberation can be inferred from the circumstances, such as the manner of the weapon’s use and the nature of the wounds. Given that witnesses saw Matthews target Robinson, chase her when she fled, and then shoot her five times in the back, the Court found that the jury could reasonably infer the necessary mental state for capital murder.
Matthews also attempted to challenge the sufficiency of the evidence regarding his identity as the killer. However, the Court declined to address this secondary argument because Matthews had failed to raise it in his directed-verdict motion during the trial, meaning the issue was not properly preserved for appeal.
Post-Invocation Statements Admissible
The second point of appeal concerned statements Matthews made to police after his arrest. Matthews initially invoked his right to remain silent and requested a lawyer, as guaranteed under Miranda and Edwards v. Arizona.
Crucially, the Court found that this invocation did not end the interrogation. As soon as the police acknowledged his request for counsel, Matthews immediately interjected, signaling a willingness to continue answering questions. The Supreme Court cited established precedent holding that if the accused “initiates further communication, exchanges, or conversations with the police,” subsequent voluntary statements are admissible. Therefore, the statements expressing remorse and blaming police were correctly allowed at trial.
Curative Instruction Deemed Sufficient Remedy for Witness Blunder
Thirdly, Matthews sought a mistrial after a police officer, while narrating body-camera footage, blurted out that a bystander had identified Matthews as the shooter. This comment allegedly violated a pretrial order barring the State from playing the audio portion of that footage.
The trial court denied the mistrial but immediately issued a curative instruction, directing the jury to disregard the officer’s unsolicited statement. The Supreme Court affirmed this decision, stating that a curative instruction is generally the sufficient remedy for an unsolicited witness comment, unless the error is so egregious that no instruction could correct it. The Court pointed out that since four eyewitnesses had already testified identifying Matthews as the shooter, the officer’s stray comment—which the jury was told to ignore—was unlikely to have caused irreparable prejudice warranting a mistrial.
Best-Evidence Rule Not Violated
Finally, Matthews argued that allowing an officer to testify about the contents of a poor-quality interrogation recording violated the best-evidence rule (Arkansas Rule of Evidence 1002).
The Court found this argument unpersuasive, noting that the rule applies when a party tries to prove the *content* of a recording without producing the recording itself. In this case, the State had already played the recording for the jury—the “best evidence.” The subsequent testimony by the officer was merely supplemental commentary on the low-quality audio. Furthermore, the Court noted that if Matthews was claiming the testimony was inadmissible hearsay, the officer’s repetition of Matthews’s own statements would qualify as an admission by a party opponent, making it admissible anyway.
Justice Karen R. Baker wrote a separate concurrence, agreeing with the outcome but emphasizing that the Court must be careful to use its own, long-standing standard for sufficiency of the evidence reviews, rather than relying solely on federal habeas corpus precedent cited by the majority.
Ultimately, the Arkansas Supreme Court found no reversible error in the trial proceedings, affirming Matthews’s capital murder conviction and life sentence.