Randy William Gay has been convicted of murder three times, the last time in Garland County, Arkansas, the county that includes Hot Springs. In 1978 he was convicted of murder in the second degree in the death of his father-in-law. In 1991 he was convicted of murder in the second degree in the death of his father. Each time he served a sentence and returned to the community. On May 10, 2011, Connie Ann Snow, a 49-year-old woman, died in Garland County, and Gay was arrested within days. In March 2015 a jury in the Garland County Circuit Court found him guilty of capital murder and recommended a sentence of death. The Arkansas Supreme Court affirmed the conviction and sentence in December 2016, and the sentence stood through a further round of state post-conviction review that ended in 2022.
Gay was born on September 1, 1958.
His criminal record began when he was about 19. In 1978 he was convicted of murder in the second degree in the death of his father-in-law. The sentence was two years, and he served that time and was released. In 1991, when he was about 32, he was convicted of murder in the second degree in the death of his father. For that conviction he served about eight years before an early release on parole. These two convictions later became central to the 2015 trial, because the prosecution relied on them as aggravating circumstances.
Connie Ann Snow was 49 years old. She died on Tuesday, May 10, 2011, in Garland County. Gay was arrested within days, in May 2011, and was first charged with murder in the second degree. The charge was later raised to capital murder, and the case was filed in the Garland County Circuit Court as No. 26CR-11-428.
The first trial took place in 2013. Before it began, the circuit court ordered Gay to undergo a mental evaluation over his objection. He refused to take part, and the results were never introduced at any trial. The 2013 trial ended in a mistrial after jurors disobeyed the court's instructions and carried out their own research on the case. That left the charge pending and sent the case to a second jury.
The retrial was heard before Judge John Homer Wright in the Garland County Circuit Court, and Gay was represented by a public defender, Mark Fraiser. On March 17, 2015, the jury found Gay guilty of capital murder. In the sentencing phase that followed, the prosecution relied on the two earlier convictions for murder in the second degree as aggravating circumstances. The jury recommended death, and the sentence was imposed on March 19, 2015.
Mark Fraiser, as a full-time public defender, asked the Arkansas Supreme Court on December 10, 2015, to be relieved from the appeal because he was not eligible for compensation for appellate work. The court granted the motion in a per curiam order that day under Ark. Code Ann. section 19-4-1604(b)(2)(B) and appointed Dale Adams to represent Gay. In April 2016 the court granted Gay an extension of time to file a supplemental record.
The court decided the case on December 8, 2016, in Gay v. State, 2016 Ark. 433, in an opinion by Justice Karen R. Baker. It affirmed. Gay had argued that the jury saw his entire record from the Division of Correction, and the court held the claim unpreserved because he had introduced the material himself without objection. It also rejected his challenges to questions put to prospective jurors about the death penalty, to the removal of jurors for cause, and to the instructions given on the elements of the offense. It held that he suffered no prejudice from the mental evaluation, since he refused it and the results were not used. It declined to revisit its earlier decision that a trial court need not instruct jurors that lingering doubt about guilt is a mitigating circumstance, and it found no error in refusing a proposed mitigating circumstance for which Gay had offered no evidence. A review of the entire record found no reversible error.
Gay then petitioned for post-conviction relief under Rule 37.5 of the Arkansas Rules of Criminal Procedure. After a hearing, the Garland County Circuit Court denied the petition. On appeal, in Gay v. State, 2021 Ark. 3, decided January 21, 2021, he raised six issues: the fairness of the jury, eight claims of ineffective assistance of counsel, the death-penalty jury instructions, sentencing requirements, ambiguous verdict forms, and a prosecutor's argument about lack of remorse. The Supreme Court reversed and remanded on one narrow ground. The circuit court had not made the written findings that Rule 37.5(i) requires on his last ineffective-assistance claim, which concerned trial counsel's handling of the aggravating circumstances based on the two earlier murder convictions. The court gave the circuit court sixty days from the mandate to enter a compliant order and barred new claims.
The circuit court held a further hearing and again denied relief. The Arkansas Supreme Court affirmed on February 10, 2022, in case CR-21-202. Rehearing was denied on March 31, 2022, and on April 14, 2022, the court denied a motion to stay the mandate, with three justices voting to grant it.
Gay's federal habeas corpus case was filed in the United States District Court for the Western District of Arkansas, Hot Springs Division, as No. 6:23-cv-06011. On July 16, 2026, the United States Court of Appeals for the Eighth Circuit, in No. 26-1877, denied his application for a certificate of appealability "in its entirety" and dismissed the appeal. Judges Loken, L.R. Smith and Grasz heard the matter. His federal public defender then applied to the United States Supreme Court for more time, and on September 23, 2026, Justice Kavanaugh extended the deadline for a petition for a writ of certiorari to December 13, 2026. The intended petition raises the claim that Gay was denied his Sixth Amendment right to counsel of his choice and challenges the Eighth Circuit's handling of the certificate.
As of November 4, 2026, Gay was one of 22 men on Arkansas's death row, with a date of sentence of March 19, 2015, from Garland County. He has not been executed and no execution date has been reported.
In Arkansas a death sentence follows a separate sentencing phase before the same jury. The prosecution must prove aggravating circumstances, and the defense may present mitigating circumstances. A direct appeal goes to the Arkansas Supreme Court, which in capital cases examines the whole record for reversible error. Post-conviction relief under Rule 37.5 is a separate proceeding that begins in the trial court and returns to the Supreme Court, as it did for Gay in 2021 and 2022. Only after those stages can a prisoner seek federal habeas relief, where a certificate of appealability is required to appeal a denial. In his case that step was refused by the Eighth Circuit in 2026.
Gay was convicted in each of the three deaths, and none of them is contested as to conviction. The dates of the two earlier deaths have not been reported.
September 1, 1958: Born.
1978: Convicted of murder in the second degree in the death of his father-in-law.
1991: Convicted of murder in the second degree in the death of his father.
May 10, 2011: Connie Ann Snow, 49, dies in Garland County.
May 2011: Gay is arrested and charged with murder in the second degree.
2013: First trial ends in a mistrial after jurors conduct their own research.
March 17, 2015: Jury finds Gay guilty of capital murder.
March 19, 2015: Death sentence imposed after the jury's recommendation.
December 10, 2015: Supreme Court replaces trial counsel on the appeal.
December 8, 2016: Arkansas Supreme Court affirms, 2016 Ark. 433.
January 21, 2021: Supreme Court reverses a Rule 37.5 denial and remands for written findings, 2021 Ark. 3.
February 10, 2022: Supreme Court affirms the denial of post-conviction relief.
March 31, 2022: Rehearing denied.
April 14, 2022: Motion to stay the mandate denied.
July 16, 2026: Eighth Circuit denies a certificate of appealability.
September 23, 2026: Deadline to petition the United States Supreme Court extended to December 13, 2026.
November 4, 2026: Division of Correction death row list shows Gay under sentence from Garland County.