Rachael Lynn Dukes v. State of Arkansas

── Rachael Lynn Dukes v. State of Arkansas ── Court: Court of Appeals of Arkansas Date: April 22, 2026 Category: General Cite as 2026 Ark. App. 242 ARKANSAS COURT OF APPEALS DIVISION II No. CR-25-466 RACHAEL LYNN DUKES Opinion Delivered: April 22, 2026 APPELLANT APPEAL FROM THE CRAWFORD COUNTY CIRCUIT COURT V. [NO. 17CR-24-278] STATE OF ARKANSAS HONORABLE MARC MCCUNE, APPELLEE JUDGE AFFIRMED IN PART; REVERSED AND DISMISSED IN PART RAYMOND R. ABRAMSON, Judge A Crawford County jury found Rachael Dukes guilty of three counts of introduction of a controlled substance into the body of another person—specifically, MC1, MC2, and MC3 (counts 1, 2, and 3, respectively); and one count of first-degree murder (count 4) with an enhancement because the offense occurred in the presence of a minor. Dukes brings this appeal, arguing (1) that there was insufficient evidence to support her conviction for first- degree murder under a theory of felony murder; (2) that there was insufficient evidence to support her convictions for counts 2 and 3;1 and (3) that the circuit court erred when it 1 Dukes does not appeal her conviction for introduction of a controlled substance into MC1. allowed evidence of Dukes’s prior DHS involvement under Arkansas Rule of Evidence 404(b). We affirm in part and reverse and dismiss in part. I. Background On March 30, 2024, Crawford County 911 received a call concerning an infant, later identified as MC1, who was not breathing. MC1 was transported to Baptist Health in Van Buren where he passed away. At the time of his death, MC1 was three months and two days old. MC1’s death was initially investigated as a sudden, unexplained infant death. Van Buren Police Lieutenants Jay Baker and Randall Allen interviewed Dukes and asked her to describe what occurred during the time up to and including when she found MC1 unresponsive. She told them that MC1 had a small cough and some mild congestion that she treated with some cough medicine but that MC1 was otherwise fine when she woke up in the early morning to give him his bottle before going back to sleep. When she woke up later that morning, she noticed that MC1 was unresponsive in his basinet, and she ran to her neighbor’s apartment. The officers collected the bottle Dukes used to feed MC1 before his death. Dukes denied that she was using any controlled substances at the time. On May 21, 2024, MC1’s toxicology report was returned, and it reflected that MC1 had methamphetamine in his system. Baker interviewed Dukes again, and Dukes professed to have no knowledge of how the methamphetamine ended up in MC1’s system. Thereafter, the crime lab tested the liquid from the bottle collected after MC1’s death and determined that it was positive for the presence of methamphetamine. During this period, Lieutenant Baker was further informed that MC1 had a healing fracture on the back of his skull. He 2 then reinterviewed Dukes, who said that MC1 had fallen from her bed to the floor a couple of weeks before his death, but at the time, she did not believe he had fallen hard. The medical examiner testified that the fracture on MC1’s skull was not consistent with a fall to a flat surface, but rather was the result of blunt-force trauma. After executing numerous search warrants, Lieutenant Baker found a series of text messages from Dukes. The text messages show that in the months leading up to MC1’s death, Dukes texted various individuals seeking to