James Edward Arnold v. State of Arkansas

── James Edward Arnold v. State of Arkansas ── Court: Court of Appeals of Arkansas Date: March 18, 2026 Category: General Cite as 2026 Ark. App. 183 ARKANSAS COURT OF APPEALS DIVISION IV No. CR-25-190 JAMES EDWARD ARNOLD Opinion Delivered March 18, 2026 APPELLANT APPEAL FROM THE FRANKLIN COUNTY CIRCUIT COURT, V. NORTHERN DISTRICT [NO. 24OCR-23-145] STATE OF ARKANSAS APPELLEE HONORABLE JAMES DUNHAM, JUDGE AFFIRMED RAYMOND R. ABRAMSON, Judge James Arnold was found guilty of one count of trafficking a controlled substance and one count of felony failure to appear. Arnold was sentenced to 180 months’ incarceration in the Arkansas Division of Correction on count one, and 60 months’ incarceration on count two, to run consecutively. Arnold brings his current appeal on two grounds: (1) there was insufficient evidence to support his conviction of failing to appear; and (2) his arrest violated the Equal Protection Clause. I. Background On May 12, 2023, Ozark Police Officer Tyler Williams initiated a traffic stop after he witnessed the vehicle pass the fog line. At the stop, Arnold was identified as the driver of the vehicle while his passenger was identified as the owner of the vehicle. Officers Williams and Bryce Cobb testified that they smelled marijuana emanating from the vehicle when the windows were rolled down. After speaking with Arnold for some time while filling out a warning ticket for the traffic violation, officers began a probable-cause search of the vehicle due to the smell of marijuana. The search of the vehicle revealed 2.4 pounds of marijuana and 8.1 pounds of psilocybin-infused chocolate bars. Upon being arrested, Arnold spontaneously informed officers that his passenger was “just giving me a ride, she didn’t know anything.” Thomas, Arnold’s passenger, told the officers that she had some marijuana in her possession but that she had a medical marijuana card out of Oklahoma. Officers reviewed Thomas’s medical marijuana card and confirmed that she had less than 2.5 grams of marijuana—the legal amount of marijuana she could carry with her medical marijuana card—in her second purse located in the backseat of the vehicle. Thomas denied knowledge of any other controlled substances in the vehicle. II. Failure to Appear A directed-verdict motion is a challenge to the sufficiency of the evidence. LeFever v. State, 91 Ark. App. 86, 208 S.W.3d 812 (2005). When the sufficiency of the evidence is challenged, this court considers only the evidence that supports the verdict, viewing the evidence in the light most favorable to the State. Id. The test is whether there is substantial evidence to support the verdict, which is evidence that is of sufficient force and character that it will, with reasonable certainty, compel a conclusion one way or another. Id. Furthermore, challenges to an evidentiary ruling are reviewed under the abuse-of- discretion standard. Baumann v. State, 2018 Ark. App. 564, 566 S.W.3d 494. This court will not reverse the circuit court’s ruling absent a showing of manifest abuse. James v. State, 2021 Ark. 2 App. 33, 616 S.W.3d 267. Abuse of discretion is a high threshold that does not simply require error in the circuit court’s decision but requires that the circuit court act improvidently, thoughtlessly, or without due consideration—prejudice must have also resulted. Id. Arnold argues that there was insufficient evidence t