Arkansas Supreme Court affirms Dylan Collins’ capital-murder conviction, upholds voir-dire limits

The Arkansas Supreme Court on Sept. 25, 2025, affirmed the conviction of Dylan Collins for capital murder and upheld a trial judge’s restriction on voir dire questions about legal burdens of proof. Collins was sentenced to life in prison plus 10 years for a firearm enhancement.

The case stems from a Jan. 14, 2023, interstate shooting near Maumelle in which Collins fired 13 times into a truck driven by Arva Wilkerson. Wilkerson was shot four times and died the following day. According to the opinion written by Associate Justice Cody Hiland, Collins drove home to Marion after the shooting, destroyed the firearm and did not notify police. Collins was identified as a suspect after Wilkerson gave a partial license‑plate number in a 911 call; during a recorded interview with Mayflower investigator Taylor Decker, Collins initially denied involvement then characterized the shooting as self‑defense, saying he “hopped out like this and asked him, why was he following me? [Wilkerson] instantly came to a complete stop and went for his gun.”

The State presented eyewitness testimony that there was no interaction between Collins and Wilkerson before the shooting and that Collins “immediately got out and took a few steps towards [Wilkerson’s] truck,” lifted a gun and began firing, testimony the opinion attributes to witness Kristen Young. Police later found a pistol in Wilkerson’s closed center console. The trial court denied the defense’s motions for a directed verdict at the close of the State’s case and again after the defense rested.

On appeal Collins argued the State failed to introduce substantial evidence negating his justification (self‑defense) defense. The Supreme Court reviewed the record in the light most favorable to the State and concluded there was sufficient evidence for a reasonable jury to reject Collins’s version of events. The court cited Arkansas Code Annotated § 5‑2‑607—defining when a person is justified in using deadly physical force—and explained that the jury could find Collins was the initial aggressor and that he did not actually see Wilkerson with a weapon, making his claim of reasonable belief in imminent deadly force one the jury could discredit.

Collins also challenged the trial court’s limitations on voir dire. Defense counsel had sought to contrast the beyond‑a‑reasonable‑doubt standard with other burdens of proof such as preponderance of the evidence and clear and convincing evidence as a demonstrable aid to jurors. The trial judge sustained the State’s objection and told counsel the court would not permit questioning about other standards because jurors would not be instructed on them. The Supreme Court found no abuse of discretion in that decision, citing the wide latitude afforded trial judges under Arkansas Rule of Criminal Procedure 32.2(a) and case law that permits limiting potentially confusing voir‑dire questioning.

The opinion notes the trial court instructed the jury on the statutory elements of justification and that justification, when raised, becomes an element the State must disprove beyond a reasonable doubt (Ark. Code Ann. § 5‑1‑102(5)(C)). The court affirmed the denial of the directed‑verdict motions, the conviction for capital murder and the sentence of life imprisonment plus ten years for the firearm enhancement.

The court also stated it reviewed the record under Arkansas Supreme Court Rule 4‑3(a) for any adverse rulings and found no prejudicial error. Appellate counsel for Collins were William O. “Bill” James Jr. and Drew Curtis of the James Law Firm; the State was represented by Attorney General Tim Griffin and Assistant Attorney General Jacob Jones.