ARKANSAS, USA — The Arkansas Supreme Court affirmed the resentencing of a Fayetteville man who was convicted of sexually assaulting and killing a 4-year-old child in 1986.
Christopher Segerstrom was originally sentenced to life without the possibility of parole for 4-year-old Barbara Thompson's death in 1987. In August 2022, Segerstrom was resentenced to life in prison but with the possibility of parole.
Segerstrom was a 15-year-old when he was convicted of capital murder for sexually assaulting and killing Thompson. He is accused of hitting Thompson on the head with a rock and suffocating her in a wooded area near the University of Arkansas.
In April 2017, the State of Arkansas filed a motion for resentencing in Washington County Circuit Court under the Fair Sentencing of Minors Act of 2017 after the U.S. Supreme Court and Arkansas Supreme Court ruled that juveniles could not be sentenced to life without parole, meaning anyone who was sentenced as a teen to life without parole has to be resentenced.
He was released from the Arkansas State Hospital in 2022. Court records show he was diagnosed with schizophrenia and an antisocial personality disorder, but it was determined that Segerstrom was fit for resentencing.
However, one doctor determined Segerstrom's "schizophrenic delusions" rendered him unfit for sentencing, while another doctor said there was no evidence to show that he suffered from a psychotic disorder like schizophrenia.
During the resentencing trial, a doctor from the Arkansas State Hospital testified that while Segerstrom has a low IQ, he believes that the convicted killer does have the mental capacity to act out to "get what he wants."
The medical examiner, who performed an autopsy on the victim and testified at the 1987 trial, also testified at the resentencing trial. The state admitted the testimony under the "hearsay exception," meaning the defense could not do a cross-examination.
After the evidence was presented, Segerstrom referenced Miller v. Alabama and proffered a jury instruction that they must take into account that minors are "constitutionally different" than adults in light of the sentencing.
The court rejected the instruction and sentenced Segerstrom to life in prison.
Appeal and Arkansas Supreme Court's Opinion
After the sentencing, Segerstrom filed an appeal against the ruling that he was fit to proceed with the trial, denying his request for a continuance, granting the state's motion to admit prior trial testimony, and rejecting his jury instruction.
Segerstrom argued expert witnesses delivered conflicting testimonies on whether he was fit to stand trial or not.
The court's opinion, which Associate Justice Barbara Webb delivered, states it is not the Arkansas Supreme Court's duty to reweigh testimonies of medical experts.
"Segerstrom possessed a factual and rational understanding of the criminal proceedings against him, as well as the capacity to rationally assist in his own defense and communicate with his attorney," Webb wrote.
Additionally, Webb wrote that the circuit court was within its discretion to deny Segerstrom's continuance. Webb cited a criminal procedure that says a court should grant a continuance only after a "good cause" is shown.
During the trial, Segerstrom objected to the state's motion to admit the medical examiner's testimony, claiming the defense had a different motive to cross-examine in the second trial than they did in the 1987 trial. Segerstrom argued that his counsel did not introduce mitigating evidence to the doctor's original testimony because they knew he would only be sentenced to life without parole.
The defense said they planned to question the doctor about the sophistication of the crime and Segerstrom's mental health this time around. Webb said the circuit court correctly submitted the doctor's testimony.
"As the circuit court correctly noted, matters of Segerstrom’s mental health and the sophistication of the crime are outside the scope of [the doctor's] expertise as a medical examiner," Webb wrote.
Finally, Webb says Segerstrom was not entitled to a jury instruction because Miller v. Alabama has no standing for sentences lower than life-without-parole sentences.
"We hold that the court did not abuse its discretion when it refused to give Segerstrom’s instruction," Webb wrote.
The Arkansas Supreme Court ultimately determined that the Washington County Circuit Court did not make an error in resentencing Segerstrom to life in prison.
See the court's full opinion here.
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