Arnold v. State, 561 S.W.3d 727 (Ark. 2018). · Go Syfert
Arnold v. State, 561 S.W.3d 727 (Ark. 2018). Cases Citing This Book View Copy Cite
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Chris Anthony ARNOLD
v.
STATE of Arkansas
No. CR-18-15.
Supreme Court of Arkansas.
Dec 6, 2018.
Published opinion
561 S.W.3d 727
William R. Simpson, Jr., Public Defender, by: Clint Miller, Dep. Public Defender, for appellant., Leslie Rutledge, Att'y Gen., by: Jason Michael Johnson, Ass't Att'y Gen., for appellee., Officers from the Sherwood Police Department were dispatched to the victim's home to investigate a homicide. Detective Kisha Slaton testified at a pretrial hearing that Pauline stated, "Well, my son was just over here [at the house fishing] last night, and he didn't say there was anything wrong with her." Detective Slaton asked Pauline to call Arnold and then told Arnold to meet the officers at the police department for an interview. Emergency personnel later arrived and pronounced Maureen dead at the scene. Officers observed bruising, blood, and possible trauma to Maureen's face. A dark-colored scarf was tied around her neck, and her undergarments were found lying approximately five feet away. Officers also noticed a chemical odor consistent with bleach. They retrieved an off-white piece of a latex glove and a small blue piece of plastic and sent the two objects to the Arkansas State Crime Laboratory for testing. An autopsy revealed that Maureen's cause of death was ligature strangulation. Subsequent testing revealed that Arnold's DNA was present on both of Maureen's hands. Tests also confirmed the presence of Arnold's DNA on the pieces of latex glove and plastic., On February 13, 2017, the State filed a felony information charging Arnold with one count of capital murder for Maureen's death. Following a two-day jury trial in September 2017, the jury convicted Arnold of the lesser-included offense of first-degree murder and sentenced him to a term of life imprisonment in the Arkansas Department of Correction. He timely filed his notice of appeal., Arnold's sole point on appeal is that the circuit court erred in denying his motion for directed verdict. Specifically, Arnold does not dispute the elements of the first-degree-murder offense, as defined in Arkansas Code Annotated section 5-10-102(a)(2) (Supp. 2017). He challenges the sufficiency of the DNA evidence that was used to prove his identity as the person who purposely caused Maureen's death. He concedes that he was at Maureen's home on the night of the murder but contends that the State's evidence was purely circumstantial because his DNA was only on the victim's hands and on the two objects found at the scene--a portion of a latex glove and a piece of plastic., An appeal from the denial of a motion for a directed verdict is treated as a challenge to the sufficiency of the evidence. Taffner v. State , 2018 Ark. 99, 541 S.W.3d 430. In reviewing a challenge to the sufficiency of the evidence, we determine whether the verdict is supported by substantial evidence. Howard v. State , 2016 Ark. 434, 506 S.W.3d 843. Substantial evidence is evidence that is of sufficient force and character that it will, with reasonable certainty, compel a conclusion one way or the other, without resorting to speculation or conjecture. Id. In reviewing a sufficiency challenge, we view the evidence in the light most favorable to the State, considering only evidence that supports the verdict. Id., This court makes no distinction between circumstantial and direct evidence when reviewing for sufficiency of the evidence. Williams v. State , 338 Ark. 97, 991 S.W.2d 565 (1999). Circumstantial evidence may provide a basis to support a conviction, but it must be consistent with the defendant's guilt and inconsistent with any other reasonable conclusion. Moore v. State , 372 Ark. 579, 279 S.W.3d 69 (2008). Whether the evidence excludes every other hypothesis is left for the jury to decide. Id. Further, this court has consistently accepted DNA evidence as proof of guilt. Engram v. State , 341 Ark. 196, 15 S.W.3d 678 (2000)., In compliance with Arkansas Supreme Court Rule 4-3(i), the record has been examined for all objections, motions, and requests made by either party that were decided adversely to appellant, and no prejudicial error has been found.
Cited by 5 opinions  |  Published

Affirmed.