## Facts

- Robert Christian Walker, age 14, was at a pond near Jacksonville, Arkansas, with friends who had firearms, including a .22-caliber rifle.
- Walker asked to use the .22 rifle, fired once into the pond, and later discharged the rifle again; the bullet struck and killed Edward Cooper, who was fishing with his family about 532 feet away.
- Witness accounts conflicted on whether Walker cocked and aimed the rifle at Cooper and whether Walker made a racial remark before firing.
- Walker testified he did not cock the rifle, denied making the racial remark, and claimed he pointed the gun generally in Cooper’s direction and pulled the trigger, after which the gun fired and he dropped it.
- Walker was charged in circuit court with first-degree murder; his pretrial motion to transfer to juvenile court was denied and that denial was affirmed on interlocutory appeal.
- At trial, the jury was instructed on first-degree murder, second-degree murder, manslaughter, and negligent homicide, and convicted Walker of manslaughter; he received a ten-year sentence.

## Issues

1. Whether the circuit court, having acquired jurisdiction over a properly filed first-degree murder charge against a juvenile, lacked jurisdiction to enter judgment and sentence on the lesser-included offense of manslaughter.

## Decision

- The Arkansas Supreme Court affirmed the manslaughter conviction and ten-year sentence.
- The court held that the circuit court acquired jurisdiction upon the filing of the first-degree murder charge and retained jurisdiction to convict and sentence Walker for the lesser-included offense of manslaughter.
- The court rejected Walker’s post-verdict request to transfer the case to juvenile court for sentencing.

## Legal Principles

- When a circuit court properly acquires jurisdiction over a juvenile case by the filing of a qualifying offense that permits adult prosecution, the court retains jurisdiction through final judgment.
- Jurisdiction over a charged greater offense carries authority to adjudicate and sentence on properly instructed lesser-included offenses returned by the jury.
- Statutes allocating juvenile-court authority do not require transfer to juvenile court after verdict merely because the conviction is for a lesser-included offense that, if charged alone initially, might fall within juvenile jurisdiction.
- A prior appellate affirmance of a denial of transfer to juvenile court confirms the circuit court’s authority to proceed on the case as charged and is not undone by a lesser-included verdict.

## Conclusion

The court held that because the State properly filed a first-degree murder charge in circuit court against a juvenile, the circuit court maintained jurisdiction to accept a jury verdict for the lesser-included offense of manslaughter and to impose sentence, notwithstanding that manslaughter would ordinarily be addressed in juvenile court if charged alone.


Walker v. State, 309 Ark. 23, 827 S.W.2d 637 (Ark. 1992)