Amanda Jill Sharp v. State of Arkansas
588 S.W.3d 770
Ark. Ct. App.2019Background
- Amanda Jill Sharp was arrested Sept. 25, 2016 after arriving at Deputy John Eric Glidewell’s home early morning, loudly demanding entry, and striking/kicking his front door and siding; property was damaged.
- Charged with first-degree criminal mischief (>$1,000) and criminal trespass; bench trial requested; bench warrant issued Oct. 4; trial Jan. 14, 2019.
- Two forensic evaluations by Dr. Julia M. Wood diagnosed schizoaffective disorder and methamphetamine-use disorder; Dr. Wood found Sharp fit to stand trial but opined she could not appreciate the criminality of her conduct or conform her behavior at the time of the offense.
- Glidewell testified Sharp was high on meth at the time, described her conduct and the physical damage (estimate and later insurance-adjusted recovery), and testified to prior encounters with meth-intoxicated and schizophrenic persons.
- Trial court (as factfinder) denied Sharp’s motion to dismiss, rejected the mental-disease affirmative defense (crediting Glidewell’s testimony that conduct was meth-induced), convicted Sharp, sentenced her as a habitual offender to 15 years (8 suspended), and ordered $2,380.77 restitution.
- Sharp appealed arguing (1) insufficient evidence of intent, (2) insufficient proof damages exceeded $1,000, and (3) trial court erred in rejecting her mental-disease defense; the Court of Appeals affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence of intent for 1st-degree criminal mischief | State: facts (early-morning arrival, loud music, striking/kicking door despite threats) support inference of purposeful damage | Sharp: lacked requisite intent; claimed she went to "save her own life" | Court: Evidence viewed favorably to State was substantial to infer intent; conviction affirmed |
| Sufficiency of proof that damages exceeded $1,000 | State: presented damage estimates and insurance-adjusted recovery supporting >$1,000 threshold | Sharp: argued State failed to prove amount exceeded $1,000 | Court: Issue not preserved on appeal (defendant failed to renew motion on this ground at close of all evidence); not reached on appeal |
| Mental-disease or defect affirmative defense (Ark. Code §5-2-312) | State: no medical rebuttal but witness testimony indicated Sharp was intoxicated; expert report relied heavily on defendant’s statements and had credibility issues | Sharp: Dr. Wood’s two evaluations showed schizoaffective disorder causing inability to appreciate criminality or conform conduct | Court: Factfinder credited Glidewell over Dr. Wood, found defendant failed to prove defense by preponderance; court properly rejected the affirmative defense |
Key Cases Cited
- Foster v. State, 467 S.W.3d 176 (Ark. App. 2015) (standard for reviewing sufficiency of evidence: substantial evidence test)
- Ridling v. State, 203 S.W.3d 63 (Ark. 2005) (weight and credibility of evidence are for the factfinder)
- Marcyniuk v. State, 373 S.W.3d 243 (Ark. 2010) (defendant bears burden to prove mental-disease defense by preponderance)
- Davis v. State, 246 S.W.3d 862 (Ark. 2007) (factfinder is sole arbiter of whether affirmative defense proved)
- Navarro v. State, 264 S.W.3d 530 (Ark. 2007) (appellate review asks whether any substantial evidence supports verdict rejecting defense)
- Cole v. State, 802 S.W.2d 472 (Ark. App. 1991) (intent generally inferred from circumstances)
- Martinez v. State, 545 S.W.3d 264 (Ark. App. 2018) (factfinder may draw on common knowledge and experience to infer intent)
- Lee v. State, 532 S.W.3d 43 (Ark. 2017) (presumption one intends natural and probable consequences of one’s acts)
- Satterfield v. State, 448 S.W.3d 211 (Ark. App. 2014) (factfinder resolves conflicting testimony, including expert opinion)