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Jonathan Kavon Richmond v. State of Arkansas

2025-09-03

Summary

Holding. The court affirmed the revocation of the appellant's suspended imposition of sentence and granted counsel's motion to withdraw.

Jonathan Richmond appealed the revocation of his suspended imposition of sentence (SIS) for aggravated assault on a family or household member. Richmond had been sentenced to six years SIS in 2018 with conditions including payment of fines and costs at $60 monthly and no offensive contact with the victim. The State petitioned to revoke his SIS, alleging violations including failure to pay court-ordered obligations and offensive contact with the victim, later adding a new conviction for third-degree domestic battery. At the revocation hearing in May 2024, the State presented a payment ledger showing Richmond had not paid since September 2019 and introduced a certified conviction from May 2024. Richmond testified that he stopped making payments after COVID-19 disrupted his payment process and that he had moved to California to care for his sick mother. The circuit court found Richmond violated his SIS by committing the new offense and sentenced him to three years imprisonment followed by three years SIS.

Richmond's counsel filed a no-merit brief and motion to withdraw pursuant to Anders v. California. The appellate court examined whether any arguable issues of merit existed. Finding that the State introduced a certified conviction proving Richmond committed a new offense in violation of his SIS terms, the court determined the revocation was supported by sufficient evidence. The court also found no merit to Richmond's implicit request for a lesser sentence, noting the circuit court acted within its discretion and statutory sentencing guidelines.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Sufficiency of evidence to revoke suspended sentence based on new criminal conviction
  • Evidentiary rulings and exclusion of testimony at revocation hearing
  • Circuit court discretion in sentencing within statutory guidelines during revocation proceeding

Procedural posture

This is an appeal from a circuit court order revoking the appellant's suspended imposition of sentence and imposing a new sentence of three years imprisonment followed by three years SIS.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

Cite as 2025 Ark. App. 408

ARKANSAS COURT OF APPEALS

DIVISION III

No. CR-24-361

JONATHAN KAVON RICHMOND Opinion Delivered September 3, 2025

APPELLANT

APPEAL FROM THE SEBASTIAN

COUNTY CIRCUIT COURT, FORT

V. SMITH DISTRICT

[NO. 66FCR-18-809 ]

STATE OF ARKANSAS

APPELLEE HONORABLE STEPHEN TABOR,

JUDGE

AFFIRMED; MOTION TO

WITHDRAW GRANTED

WAYMOND M. BROWN, Judge

Appellant Jonathan Richmond appeals the Sebastian County Circuit Court’s order

revoking his suspended imposition of sentence (SIS) for the underlying offense of aggravated

assault on a family or household member and sentencing him to three years’ imprisonment

followed by three years’ SIS. Appellant’s counsel has filed a motion to withdraw and nomerit brief pursuant to Anders v. California,1 and Arkansas Supreme Court Rule 4-3(b)2

asserting that there is no merit to an appeal. Appellant was provided a copy of his counsel’s

brief and motion and informed of his right to file pro se points for reversal; however,

1

386 U.S. 738 (1967).

2

(2023).

appellant has not filed any pro se points. We affirm appellant’s revocation and grant

counsel’s motion to withdraw.3

Appellant pled guilty to aggravated assault on a family or household member and was

sentenced to six years’ SIS by an order filed on November 29, 2018. He was ordered to pay

fines, costs, and fees. The terms and conditions of his SIS included that he not violate any

federal, state, or municipal law; that he make payments towards his fines, costs, and fees at

the rate of $60 a month, starting on February 5, 2019; and that he not have any offensive

contact with the victim. The State filed a petition to revoke appellant’s SIS on July 9,

contending that he had violated the terms and conditions of his SIS by having offensive

contact with the victim and failing to pay his court-ordered obligations. An amended

petition to revoke filed on April 11, 2024, alleged that appellant had violated his SIS by

having offensive contact with the victim, committing the new offense of third-degree

domestic battery, and failing to pay his court-ordered obligation.

Appellant’s revocation hearing took place on May 16. The State introduced

appellant’s payment ledger4 and a certified conviction from Sebastian County District Court

dated May 14. The State then rested. Appellant testified that he made his court-ordered

payments until “COVID hit[,]” and he was told to make online payments. He subsequently

3

This is the second time this appeal has been before us; we originally ordered rebriefing and denied counsel’s motion to withdraw. See Richmond v. State, 2025 Ark. App. 20.

4

The ledger showed that appellant had a balance of $2,396, and the last payment was made on September 11, 2019.

2

got an address to mail in the payments. He stated that he went to California for four or five

years during this time because his mother was sick. He said that he tried to mail payments

from California, but his sister kept telling him that the checks were returned. He admitted

that he was drawing Social Security and disability in the amount of over $1200 a month

while living in California. On cross-examination, appellant stated that he attempted to mail

payments to the courthouse at least three or four times. He said that when he called, he was

told to “refill them out and send them back in.” He agreed that he had not made a payment

since 2019. Upon questioning by the court, appellant stated that his last payment was six

months before COVID hit but explained that he was going through a bad divorce at the

time and that he lost his family, himself, and the rights to his daughter; however, he said he

was not making any excuses.

Appellant’s counsel informed the circuit court that appellant had been sentenced to

thirty days in jail and was ordered to pay fines and costs for the new conviction. Counsel

asked the circuit court to take that into consideration, but the circuit court stated that

appellant’s sentence in that case would not affect the circuit court’s sentencing decision in

the revocation case. The circuit court found that appellant had violated the terms and

conditions of his SIS by committing the new offense of aggravated assault on a family or

household member and sentenced him to three years’ imprisonment followed by three years’

SIS. The circuit court found that the sentence would satisfy appellant’s fine, costs, and fees.

The sentencing order was filed on May 24, and appellant filed a notice of appeal on May 28.

3

Because this is a no-merit appeal, Rule 4-3(b) requires the argument section of the

brief to contain “a list of all rulings adverse to the defendant made by the circuit court on all

objections, motions[,] and requests . . . with an explanation as to why each . . . is not a

meritorious ground for reversal.”5 The requirement for briefing every adverse ruling ensures

that the due-process concerns in Anders are met and prevents the unnecessary risk of a

deficient Anders brief resulting in an incorrect decision on counsel’s motion to withdraw.6

Pursuant to Anders, we are required to determine whether the case is wholly frivolous after a

full examination of all the proceedings.7

In revocation proceedings, the State has the burden of proving by a preponderance

of the evidence that a defendant violated the terms of his or her suspended sentence as

alleged in the revocation petition, and we will not reverse the circuit court’s decision to

revoke a suspended sentence unless it is clearly against the preponderance of the evidence. 8

The State need only show that the appellant committed one violation to sustain a

revocation.9 Because the determination of a preponderance of the evidence turns on

5

Ark. Sup. Ct. R. 4-3(b)(1).

6

Harvey v. State, 2022 Ark. App. 283, 646 S.W.3d 292.

7

Id.

8

Mathis v. State, 2021 Ark. App. 49, 616 S.W.3d 274.

9

Id.

4

questions of credibility and the weight to be given testimony, appellate courts defer to the

circuit court’s superior position for assessing these factors.10

The circuit court found that appellant had violated his SIS by committing a new

offense. A certified copy of appellant’s recent conviction was entered into evidence without

objection. This new conviction was in violation of the terms and conditions of appellant’s

SIS. Thus, we hold that there would be no merit to an appeal of the sufficiency of the

evidence supporting the revocation.11

The circuit court did not err in making two additional adverse rulings against

appellant. The first is when the circuit court interrupted appellant by telling him that there

was not a question in front of him. This was an evidentiary ruling that will not be reversed

absent a showing of prejudice.12 Additionally, there is no way to determine what exactly

appellant was trying to say since he did not proffer the excluded testimony to the circuit

court.13 The second seems to be a request by appellant for a lesser sentence. In a revocation

proceeding, the circuit court has discretion in the sentence imposed and is authorized to

impose any sentence that could have been imposed originally.14 Here, appellant was

10

Stewart v. State, 2021 Ark. App. 289, 624 S.W.3d 357.

11

See Winters v. State, 2023 Ark. App. 15.

12

Goodman v. State, 2025 Ark. App. 305.

13

See Bohanon v. State, 2020 Ark. App. 22, 594 S.W.3d 92.

14

Edwards v. State, 2024 Ark. App. 387, 690 S.W.3d 880.

5

sentenced within the statutory guidelines. 15 No meritorious argument could be made that

the circuit court abused its discretion in not sentencing appellant to a lesser sentence.

From our review of the record and the brief presented, we hold that counsel’s brief is

in compliance with the directives of Anders and Rule 4-3(b)(1) and that there are no issues of

arguable merit to support an appeal. Accordingly, we affirm the revocation of appellant’s

SIS and grant counsel’s motion to withdraw.

Affirmed; motion to withdraw granted.

VIRDEN and TUCKER, JJ., agree.

Brett D. Watson, Attorney at Law, PLLC, by: Brett D. Watson, for appellant.

One brief only.

15

See Ark. Code Ann. § 5-4-401(a)(5) (Repl. 2013) (the sentence for a Class D felony shall not exceed six years).

6