Richmond v. State
In Richmond v. State, 320 Ark. 566, 899 S.W.2d 64 (1995), the defendant argued that, in light of his vigorous cross-examination of State's witnesses, the prosecutor's reference to uncontradicted testimony was actually a comment on the defendant's failure to testify.
The supreme court rejected his argument and, citing Beebe v. State, 301 Ark. 430, 784 S.W.2d 765 (1990), noted that a remark was not necessarily improper when the State's evidence could have been disputed by evidence other than by the testimony of the accused.