Anderson v. State
2011 Ark. 461
Ark.2011Background
- Anderson was convicted of capital murder and sentenced to life imprisonment.
- The State's proof included Dr. Craig's autopsy findings of 27 stab wounds and a fatal gunshot wound to Jill's head.
- The circuit court admitted evidence that Jill was pregnant as motive for murder.
- The State introduced State's Exhibits 9-16, crime-scene photographs taken 8–9 hours after death.
- Anderson challenged a causation instruction (AMI Crim.2d 603) claiming improper burden-shifting.
- The court denied suppression of custodial statements made before Miranda warnings, finding most statements voluntary and spontaneous.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Causation sufficiency for capital murder | Anderson's stabbing plus officer gunfire could not suffice | State failed to prove death caused by defendant's conduct | Directed verdict denied; substantial evidence supports causation |
| Causation instruction burden shifting | Instruction shifted burden to Anderson | Instruction misapplied; preserved error | Argument not preserved; plain-error doctrine not applied; burden-shifting issue not addressed on merits |
| Admission of pregnancy evidence | Pregnancy irrelevant and prejudicial | Pregnancy shows motive and intent | Evidence admitted; relevant to motive; no abuse of discretion demonstrated |
| Admission of crime-scene photographs | Photos eight–nine hours post-mortem were prejudicial | Photographs aided understanding of crime scene | No abuse of discretion; photographs helped explain testimony; lack of ruling on prejudice preserved on appeal |
| Custodial statements and Miranda warnings | Statements before warnings were involuntary | Most statements spontaneous, not interrogation | Circuit court's denial affirmed; spontaneous statements admissible; suppression affirmed only for one portion |
Key Cases Cited
- Camp v. State, 381 S.W.3d 11 (Ark. 2011) (sufficiency-of-evidence and directed-verdict standards cited in review)
- Jackson v. State, 321 Ark. 46, 900 S.W.2d 515 (Ark. 1995) (jury credibility and medical-causation weight for death determination)
- Windsor v. State, 338 Ark. 649, 1 S.W.3d 20 (Ark. 1999) (concurrent-causes doctrine in homicide causation)
- Echols v. State, 326 Ark. 917, 936 S.W.2d 509 (Ark. 1996) (motive evidence admissibility)
- Sasser v. State, 338 Ark. 375, 993 S.W.2d 901 (Ark. 1999) (contemporaneous-objection rule and post-conviction emphasis)
- Wicks v. State, 270 Ark. 781, 606 S.W.2d 366 (Ark. 1980) (plain-error and contemporaneous objections)
- Harris v. State, 363 Ark. 502, 215 S.W.3d 666 (Ark. 2005) (plain-error doctrine limitations)
- Stone v. State, 321 Ark. 46, 900 S.W.2d 515 (Ark. 1995) (spontaneous statements and interrogation standards)
- Sweet v. State, 2011 Ark. 20, 370 S.W.3d 510 (Ark. 2011) (spontaneous custodial statements admissibility)
- Terry v. State, 309 Ark. 64, 826 S.W.2d 817 (Ark. 1992) (interrogation and custodial-recording considerations)