Mulazim Muhammad v. State of Arkansas - Criminal Conviction Appeal
Summary
The Arkansas Court of Appeals affirmed the convictions of Mulazim Muhammad for third-degree battery and leaving the scene of an accident involving injury. Muhammad was sentenced to jail time and fines for both offenses. He appealed, arguing the trial court erred in denying his directed-verdict motions and motion to strike.
What changed
The Arkansas Court of Appeals has affirmed the convictions of Mulazim Muhammad for third-degree battery and leaving the scene of an accident involving injury. Muhammad was sentenced to one year in county jail and a $2,500 fine for battery, and three years imprisonment and a $2,500 fine for leaving the scene. The appeal stemmed from the denial of his directed-verdict motions and motion to strike.
This case involves a criminal appeal where the appellate court upheld the lower court's decision. For legal professionals involved in criminal defense or prosecution, this affirms the sufficiency of evidence presented in similar cases concerning battery and leaving the scene of an accident. Compliance officers should note that convictions in such cases can lead to significant jail time and financial penalties, underscoring the importance of adherence to criminal statutes.
What to do next
- Review case law regarding directed-verdict motions and motions to strike in criminal appeals.
- Ensure documentation and evidence collection processes are robust for battery and traffic offense cases.
- Assess potential sentencing implications based on similar convictions.
Penalties
For third-degree battery: one year in county jail and a $2,500 fine. For leaving the scene of an accident: three years imprisonment and a $2,500 fine.
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March 18, 2026 Get Citation Alerts Download PDF Add Note
Mulazim Muhammad v. State of Arkansas
Court of Appeals of Arkansas
- Citations: 2026 Ark. App. 184
Docket Number: Unknown
Combined Opinion
Cite as 2026 Ark. App. 184
ARKANSAS COURT OF APPEALS
DIVISION III
No. CR-25-333
MULAZIM MUHAMMAD Opinion Delivered March 18, 2026
APPELLANT
APPEAL FROM THE PULASKI
COUNTY CIRCUIT COURT,
V. SEVENTH DIVISION
[NO. 60CR-20-3493]
STATE OF ARKANSAS
APPELLEE HONORABLE MELANIE MARTIN,
JUDGE
AFFIRMED
RAYMOND R. ABRAMSON, Judge
A Pulaski County jury convicted Mulazim Muhammad of third-degree battery and
leaving the scene of an accident involving an injury. For third-degree battery, he was
sentenced to one year in county jail and fined $2,500. For leaving the scene of an accident,
he was sentenced to three years’ imprisonment and fined $2,500. Muhammad appeals his
convictions and argues that the circuit court erred by denying his directed-verdict motions
and his motion to strike.
On March 2, 2022, the State filed a second amended criminal information against
Muhammad alleging that he committed the offenses of first-degree battery and leaving the
scene of an accident with injury or death. The case proceeded to a jury trial on February 11,
2025.
At trial, Teresa Brown testified that she had been in a romantic relationship with
Muhammad and that on August 19, 2020, she and Muhammad sat in his truck outside her
home. She stated that she told Muhammad that she wanted to end their relationship and
that their conversation “went downhill.” She explained that Muhammad “blew smoke” in
her face, and in response, she threw a drink at him and exited the truck.
Brown explained, “I get out of the vehicle and I go to shut the door and realize that I
left my house keys in the vehicle, so I pulled the door open and I reached for my keys and
then he just took off in the truck.” She later noted that he “[s]ped off” in the truck.
Brown testified that the truck’s back door hit her and a tire ran over her foot. The
State asked, “And what happened after the truck door—or I guess the door frame struck you?
Did you stay on your feet? Did you fall to the ground? What happened?” She replied, “It
knocked me all the way to the ground. And it was actually—I was on the curb . . . and I
screamed.”
Brown stated that she repeatedly called Muhammad and that he eventually picked up
on the eighth try. She testified that she told him that he hit her with the truck and that she
needed to go to the emergency room. She stated that Muhammad hung up on her and did
not return. Brown explained that she went to the hospital and had twenty-five staples in her
foot. She further stated that doctors attempted a skin graft, but the graft was unsuccessful.
During cross-examination, Brown acknowledged that on the day of the accident, she
did not report to police that she turned back to the truck to retrieve her keys. She testified
that she informed the police that she exited the vehicle and Muhammad drove away.
2
During the State’s redirect, the following colloquy took place between the prosecutor
and Brown:
Q I also want to talk again about where—what part—there’s been some confusion
here about what part of the truck hit you first. We’re not talking about—I’m
not talking about when the tire ran over your foot, but, like, when the vehicle,
the part of the vehicle that actually struck you, what part of the vehicle was
that?
A The back door.
Q Back door? Okay. Are we talking, like, where the handle is or up, like where
it’s connected to the frame?
A Where it’s connected to the frame. Not where the handle is.
Q So you’re talking the door frame is what hit you?
A Okay.
Muhammad’s counsel objected and argued that the State was leading Brown and “implying
the answer.” He also moved to strike “because it’s him answering a question for her to
answer.” The court sustained the objection and advised the State not to lead the witness, but
it refused to strike Brown’s testimony.
After the State rested its case, Muhammad moved for a directed verdict on first-degree
battery and the lesser-included offense of third-degree battery. For third-degree battery, he
argued that the State presented insufficient evidence that he acted recklessly and tried to run
over Brown. He also moved for a directed verdict on the charge of leaving the scene of the
accident, and he argued that because Brown called him and informed him that he hit her,
the evidence showed that he had no prior knowledge of the accident. He acknowledged that
3
the offense did not have a mens rea requirement, but he argued that a person has “to have
knowledge . . . before you have some duty.” The court denied the motions.
The jury found Muhammad guilty of third-degree battery and leaving the scene of an
accident involving an injury. For third-degree battery, he was sentenced to one year in the
county jail and fined $2,500. For leaving the scene of an accident, he was sentenced to three
years’ imprisonment and fined $2,500. This appeal followed.
On appeal, Muhammad argues that the circuit court erred by denying his motions for
directed verdict for third-degree battery and for leaving the scene of an accident with an
injury. A directed-verdict motion is a challenge to the sufficiency of the evidence. LeFever v.
State, 91 Ark. App. 86, 208 S.W.3d 812 (2005). When the sufficiency of the evidence is
challenged, this court considers only the evidence that supports the verdict, viewing the
evidence in the light most favorable to the State. Id. The test is whether there is substantial
evidence to support the verdict, which is evidence that is of sufficient force and character
that it will, with reasonable certainty, compel a conclusion one way or another. Id. The
credibility of the witnesses is an issue for the jury and not this court. Collins v. State, 2021
Ark. 35, 617 S.W.3d 701. A jury is not required to believe all or any part of a witness’s
statement and is entitled to draw upon common sense and experience in reaching its verdict.
Regarding the third-degree-battery conviction, Muhammad asserts that the evidence
is insufficient to show that he recklessly caused Brown’s injuries. He claims that Brown’s
testimony was inconsistent and contradictory concerning when he drove away and which
4
part of the truck struck Brown. He further points out that Brown had to call him after the
accident to inform him that he had hit her with the truck. He thus claims the evidence
showed that he was unaware that he had struck Brown.
A person commits third-degree battery if the person recklessly causes physical injury
to another person. Ark. Code Ann. § 5-13-203 (a)(2) (Repl. 2024). A person acts recklessly
with respect to attendant circumstances or a result of his conduct when the person
consciously disregards a substantial and unjustifiable risk that attendant circumstances exist
or the result will occur. Ark. Code Ann. § 5-2-202 (3)(A) (Repl. 2024). The supreme court
has repeatedly stated that intent is rarely proved by direct evidence and usually must be
inferred from the circumstances. Rollins v. State, 2009 Ark. 484, 347 S.W.3d 20.
In this case, viewing the evidence in the light most favorable to the State, we hold that
substantial evidence supports Muhammad’s conviction for third-degree battery. Brown
testified that after her disagreement with Muhammad, she exited his truck, and he hit her
with the vehicle as he sped away. It was for the jury, not this court, to determine credibility
and to resolve inconsistencies in Brown’s testimony. See Collins, 2021 Ark. 35, 617 S.W.3d
701. Accordingly, we hold that the circuit court did not err in denying Muhammad’s
directed-verdict motion for third-degree battery.
As to the conviction of leaving the scene of an accident, Muhammad asserts the
evidence is insufficient to show that he knew the accident had occurred. He relies on Brown’s
testimony that she had to call him to notify him of the accident.
Arkansas Code Annotated section 27-53-101 (Repl. 2022) provides:
5
(b)(1) The driver of a vehicle involved in an accident resulting in physical injury
or serious physical injury to or death of any person shall immediately stop the vehicle
at the scene of the accident or as close as possible to the scene of the accident, but
shall then immediately return to and remain at the scene of the accident until he or
she has fulfilled the requirements of § 27-53-103.
....
(c) If a person fails to comply with subsection (b) of this section or with § 27-53-
103 and the accident results in physical injury to another person, he or she upon
conviction is guilty of a Class D felony.
In Stivers v. State, 354 Ark. 140, 118 S.W.3d 558 (2003), the supreme court concluded that
the statute’s mandatory language is a clear indication that the accident-causing driver’s
mental state is irrelevant.
Accordingly, in this case, the State was not required to prove Muhammad’s mental
state. Even so, Brown testified that after she told Muhammad about the accident on the
phone, he ended the call and did not return. Accordingly, we hold that the circuit court did
not err in denying Muhammad’s direct-verdict motion.
Muhammad also argues that the circuit court erred by denying his motion to strike
Brown’s testimony following the prosecutor’s leading question during redirect. He argues
that the prosecutor supplied a critical fact—that the truck’s doorframe hit Brown—to Brown’s
testimony.
The decision to admit or exclude evidence is within the sound discretion of the circuit
court, and we will not reverse that decision absent a manifest abuse of discretion. Reid v.
6
State, 2019 Ark. 363, 588 S.W.3d 725. Further, will not reverse unless Muhammad
demonstrates that the ruling prejudiced him. Id.
In this case, during the State’s direct examination of Brown, the prosecutor asked
Brown about the doorframe hitting her. Evidence that is merely cumulative or repetitious of
other evidence admitted without objection cannot be prejudicial. Eliott v. State, 342 Ark.
237, 242, 27 S.W.3d 432, 436 (2000). Accordingly, we find no abuse of discretion by the
circuit court.
We therefore affirm Muhammad’s convictions.
Affirmed.
HIXSON and MURPHY, JJ., agree.
Warden Law Firm, by: Harry Warden; and Ludwig Law Firm, PLC, by: Kale Ludwig, for
appellant.
Tim Griffin, Att’y Gen., by: Dalton Cook, Ass’t Att’y Gen., for appellee.
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