Cite as 2026 Ark. App. 404
ARKANSAS COURT OF APPEALS
DIVISION III
No. CR-25-362
RANDY MEDLOCK Opinion Delivered September 16, 2026
APPELLANT
APPEAL FROM THE CRITTENDEN
COUNTY CIRCUIT COURT
V. [NO. 18CR-23-584]
STATE OF ARKANSAS HONORABLE RALPH WILSON, JR.,
APPELLEE JUDGE
AFFIRMED
RAYMOND R. ABRAMSON, Judge
A Crittenden County jury convicted Randy Medlock of one count of theft by
receiving, a Class B felony; one count of theft by receiving, a Class C felony; and one count
of fleeing, a Class A misdemeanor. Medlock was sentenced to thirty years’ incarceration in
the Arkansas Division of Correction. Medlock appeals his sentence, arguing that (1) the
Crittenden County Circuit Court did not have subject-matter jurisdiction to hear his case;
(2) there was insufficient evidence to sustain his conviction; and (3) the circuit court abused
its discretion by sentencing him to an illegal sentence. We affirm.
I. Background
On May 2, 2023, an arrest warrant was issued for Medlock. The initial arrest warrant
charged Medlock with two counts of felony theft by receiving, one count of fleeing, one
count of making a terroristic threat, one count of disorderly conduct, and three counts of possessing instruments of a crime. This was later amended to one count of Class B felony
theft by receiving; one count of Class C felony theft by receiving; and one count of Class A
misdemeanor fleeing.
Medlock was later arrested in Memphis, Tennessee, where he was held on the
Crittenden County arrest warrant. He was then extradited to Arkansas and officially served
his arrest warrant. Upon being charged, Medlock waived his right to counsel after a Faretta
v. California, 422 U.S. 806, 95 S. Ct. 2525 (1975), colloquy and also by a pro se handwritten
waiver of counsel stating that he understood his rights. Before trial, Medlock repeatedly
raised the issue of jurisdiction and was advised that the circuit court had jurisdiction, and
further, that jurisdiction was an element of the crime to be determined by the jury.
On the day of trial, Medlock, proceeding pro se, initially participated in voir dire.
During his questioning of potential jurors, Medlock repeatedly began testifying. Specifically,
Medlock told the jurors that he paid $3,600 at a pawn shop for both the camper and the
truck found on his property. After a break, Medlock refused to participate in the trial any
further, alleging that the issue of jurisdiction had not been determined, and he wished to be
removed from the proceedings. He was advised of the rights he would give up if he were
removed. He nevertheless chose to be removed.
The trial continued without Medlock’s presence, and the State called two witnesses.
The first witness was the owner of the camper, William Morrison. Mr. Morrison testified
that the camper was stolen from his property in February of 2023 and that he had
surveillance video of it being taken using the F-150 truck that was found on Medlock’s
2
property. The individual in the video matched the description of Medlock. Mr. Morrison
testified that he paid $28,000 for the camper.
The other witness for the State was Detective Dallas Watson with the Crittenden
County Sheriff’s Department. Detective Watson testified that he received multiple calls
about Medlock shooting guns on his property. Detective Watson stated that Medlock was a
known felon who was not allowed to possess guns. Following the calls to the sheriff’s office,
Detective Watson obtained a search warrant for Medlock’s white camper located in
Edmonson, Arkansas. On April 25, 2023, the Crittenden County Sheriff’s Office executed
the search warrant. They found a camper and an F-150 pickup truck located on the premises.
Upon running the camper’s VIN, officers were informed that the camper was reported stolen
in Mississippi. Likewise, the pickup truck found was reported stolen in Memphis. Inside the
camper and the pickup truck were mail and other personal belongings and paperwork that
belonged to Medlock. The owner of the F-150 pickup truck positively identified the truck as
his.
Detective Watson further testified that he received a phone call from Medlock after
they seized the stolen property. Detective Watson described Medlock as “irate” and
belligerent on the phone. Detective Watson told Medlock that he needed to turn himself in.
Following the phone call, the Crittenden County Sheriff’s Office received a tip about
Medlock’s location, and Detective Watson attempted to arrest Medlock at the Budget Inn
Hotel, but he slipped out of a back window and fled from officers on foot.
3
Finally, Detective Watson testified that he has a computer program that tracks
property sold to and by pawn shops. The program sends an alert to local law enforcement
when stolen property is sold to a pawn shop. Detective Watson testified that he never
received any notification that the camper or the F-150 truck was ever sold to or by any pawn
shop in the area. Further, Detective Watson attested that he did not find any paperwork that
showed that the camper or the truck was ever sold to a pawn shop, let alone purchased from
one by Medlock.
II. Sufficiency of the Evidence
Double-jeopardy concerns require us to first address the sufficiency challenges. Taffner
v. State, 2018 Ark. 99, at 5, 541 S.W.3d 430, 434. Preservation of an appellant’s right to
freedom from double jeopardy requires a review of the sufficiency of the evidence before a
review of trial errors. Harris v. State, 284 Ark. 247, 681 S.W.2d 334 (1984) (discussing Burks
v. United States, 437 U.S. 1 (1978)).
To the extent that Medlock argues that there was insufficient evidence to support his
conviction, this claim is not preserved for our review. To preserve a challenge to the
sufficiency of the evidence in a jury trial, a criminal defendant must make a motion for
directed verdict at the close of the evidence offered by the prosecution and at the close of all
the evidence. Ark. R. Crim. P. 33.1(a) (2025). A motion for directed verdict shall state the
specific grounds therefor. Maxwell v. State, 373 Ark. 553, 559, 285 S.W.3d 195, 200 (2008).
Without a circuit court ruling on a specific motion, there is nothing for this court to review.
Id. Failure to abide by these procedural rules renders any question of the sufficiency of the
4
evidence waived on appeal. Ark. R. Crim. P. 33.1(c); Bradley v. State, 2013 Ark. 58, 426
S.W.3d 363; Woods v. State, 2018 Ark. App. 256, 548 S.W.3d 832. Here, Medlock voluntarily
chose to be removed from the trial proceedings and, accordingly, did not move for directed
verdict. Therefore, his sufficiency-of-the-evidence argument is not preserved for our review.
III. Jurisdiction
Medlock’s pro se brief on appeal lacks coherency and is, at times, incomprehensible.
However, the main argument that Medlock ostensibly makes is the same one he made below:
that the circuit court lacked subject-matter jurisdiction over him and the case.
The issue of jurisdiction is one that can be raised at any time, even for the first time
on appeal. Baldwin v. State, 74 Ark. App. 69, 45 S.W.3d 412 (2001). However, Medlock’s
argument is meritless because the circuit court has subject-matter jurisdiction to hear and
determine cases involving violations of criminal statutes. Wolfe v. Payne, 2021 Ark. 87, 622
S.W.3d 625. Moreover, a circuit court has personal jurisdiction over persons who commit
offenses within the county over which it presides. Nichols v. State, 2023 Ark. App. 11, at 5,
659 S.W.3d 519, 523. It is undisputed that the camper and the F-150 truck were held in
Medlock’s custody in Edmonson, Arkansas, which is located in Crittenden County.
Therefore, it cannot be disputed that the Crittenden County Circuit Court had subjectmatter and personal jurisdiction over Medlock. Thus, Medlock’s jurisdictional challenge fails
on this ground.
5
IV. Illegal Sentence
Liberally interpreting Medlock’s brief, he appears to argue that his sentence is illegal
for being in “excess of the max[imum] requirement of law.” An illegal sentence is one that is
illegal on its face. Redus v. State, 2019 Ark. 44, at 4, 566 S.W.3d 469, 471. A sentence is
illegal on its face when it is void because it is beyond the circuit court’s authority to impose
it and gives rise to a question of subject-matter jurisdiction. Id. Sentencing is entirely a matter
of statute in Arkansas. Id. Sentencing shall not be other than in accordance with the statute
in effect at the time of the commission of the crime. Hale v. Hobbs, 2014 Ark. 405, at 4, 443
S.W.3d 533, 535. The general rule is that a sentence imposed that is within the maximum
term prescribed by law is not illegal on its face. McArty v. State, 2020 Ark. 68, at 7, 594
S.W.3d 54, 58; Harris v. State, 2026 Ark. App. 273, at 4, 738 S.W.3d 308, 312.
In the instant case, the jury sentenced Medlock to twenty years on count one, a Class
B felony; ten years on count two, a Class C felony; and thirty days on count three, a Class A
misdemeanor. The jury recommended that the prison terms run consecutively to each other.
In Arkansas, the sentence for a Class B felony must be between five years and twenty years’
incarceration. Ark. Code Ann. § 5-4-401(a)(3) (Repl. 2024). Likewise, the sentence for a Class
C felony must be between three and ten years’ incarceration. Id. § 5-4-401(a)(4). Finally, the
sentence for a Class C misdemeanor may not exceed thirty days. Id. § 5-4-401(b)(3).
Accordingly, the sentences imposed for each offense were within the maximum term
prescribed by law and are facially legal. Harris, 2026 Ark. App. 273, at 4, 738 S.W.3d at 312.
While the jury requested that the sentences run consecutively to each other, the amended
6
sentencing order correctly reflects that the thirty-day misdemeanor sentence runs
concurrently with the felony charges as required by Arkansas Code Annotated section 5-4-403(c)(1) (Repl. 2024). Therefore, the sentence is not illegal.
V. Conclusion
For the reasons provided, the Crittenden County Circuit Court had both subjectmatter and personal jurisdiction over Medlock for the charges against him. The circuit court
did not err in the sentence given to Medlock. Finally, Medlock did not preserve his
sufficiency-of-the-evidence argument for appeal. Accordingly, we affirm.
Affirmed.
KLAPPENBACH, C.J., and VIRDEN, J., agree.
Randy Medlock, pro se appellant.
Tim Griffin, Att’y Gen., by: Jason Michael Johnson, Ass’t Att’y Gen., for appellee.
7