Adam Lee Maskell v. State of Arkansas

── Adam Lee Maskell v. State of Arkansas ── Court: Court of Appeals of Arkansas Date: April 01, 2026 Category: General Cite as 2026 Ark. App. 203 ARKANSAS COURT OF APPEALS DIVISION I No. CR-25-226 Opinion Delivered April 1, 2026 ADAM LEE MASKELL APPELLANT APPEAL FROM THE BRADLEY COUNTY CIRCUIT COURT [NO. 06CR-22-25] V. HONORABLE QUINCEY ROSS, STATE OF ARKANSAS JUDGE APPELLEE AFFIRMED CASEY R. TUCKER, Judge Adam Maskell (Maskell) appeals from a negotiated plea to a Class B felony possession of a firearm by certain persons and the sentence of five years’ imprisonment as a habitual offender. Maskell raises seven points on appeal. Maskell’s first two arguments on appeal ask this court to hold that Judge Puryear had no jurisdiction to sign an amended order of recusal; accordingly, Judge Ross, who was appointed upon Judge Puryear’s recusal, should have recused himself because he was appointed by an order entered without jurisdiction. Third, Maskell argues that Judge Ross abused his discretion by refusing to recuse himself because he was biased against Maskell. Maskell next argues that the trial court abused its discretion by not holding an evidentiary hearing on his motion to withdraw plea and by denying his motion to withdraw plea. Finally, he argues he was denied his right to allocution and that the judge who signed his sentencing order had no jurisdiction to do so. Finding no error, we affirm. On May 25, 2022, officers discovered a firearm on Maskell’s person when he was stopped and frisked near the residence of Patrick Smith, whom Maskell had reportedly threatened that day. Maskell was charged in the Bradley County Circuit Court, and Judge Crews Puryear was assigned to Maskell’s case. Maskell, a self-claimed paralegal, was allowed to proceed pro se when he was arraigned on August 15, 2022. Maskell first confirmed that he understood the possible punishment for his charges, including Class B felony possession of a firearm by certain persons as a habitual offender. At a pretrial hearing on April 10, 2023, Maskell informed the court that he had filed a writ of mandamus and a writ of prohibition and/or a stay of proceedings alleging that Judge Puryear had tampered with evidence and aided in suppressing exculpatory evidence. The Arkansas Supreme Court denied Maskell’s petitions in a formal order dated October 28, 2022. Judge Puryear addressed Maskell’s allegations that he had been impartial toward Maskell. On April 21, 2023, Maskell filed a pro se motion seeking the disqualification of Judge Puryear. In this motion, Maskell alleged, as he had done in his petition to the Arkansas Supreme Court, that Judge Puryear received hand signals from the public defender that led to rulings against Maskell in a suppression hearing. He made several other allegations, such as witness tampering and impartiality by Judge Puryear. In the motion, he also stated that he had reported Judge Puryear for judicial misconduct. When this recusal motion was addressed 2 on May 22, 2023, Judge Puryear reiterated that he did not harbor any bias or hold any interest in the outcome, but he voluntarily recused himself. On May 22, 2023, Judge Puryear entered an order of recusal transferring the case in accordance with Ark. Sup. Ct. Admin. Order No. 16. On July 21, Judge Puryear issued an amended order for recusal that “corrected” the previous order and stated that the case would not be reassigned under Administrative Order No. 16 but rather directed the circuit clerk “to transfer this matter as per the Tenth Judicial