Bradley v. State, 2013 Ark. 58

Bradley was convicted by a Pulaski County Circuit Court jury of capital felony murder and aggravated robbery with firearm enhancements.
The crime occurred during an aggravated robbery at Evon Henderson’s home, where Henderson was killed during a confrontation involving Bradley and co-defendant Nelson.
Nelson testified that Bradley supplied a firearm and helped plan/participate in the robbery; Bradley fled with a bag of marijuana after the shooting.
Multiple witnesses—Lawrence, Ed Henderson, and law enforcement—identified Bradley's involvement and Bradley’s flight from authorities for about two months.
Bradley testified he accompanied Nelson to purchase marijuana and fled only out of fear after a gun was drawn; he denied planning or participating in the robbery.
Bradley challenges include: theft of contraband is not a basis for conviction, insufficient evidence of accomplice liability, and an objection regarding truth-in-sentencing instructions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of accomplice liability evidence	Bradley argues insufficient corroboration of Nelson’s accomplice testimony.	Bradley contends the State failed to prove he aided or encouraged the robbery that led to death.	Evidence sustains accomplice liability and underlying aggravated robbery.
Theft of contraband as basis for convictions	The State contends Bradley can be convicted of theft/robbery despite contraband ownership issues.	Bradley claims marijuana is contraband and cannot be lawfully owned, so theft/robbery convictions fail.	Sufficiency preservation issues; merits not reached due to trial-record preservation defects.
Truth-in-sentencing instruction	Bradley asserts error for not informing jury of automatic life without parole under truth-in-sentencing.	Bradley failed to preserve the issue; even if preserved, arguments lack merit.	Issue not preserved; no error found on review.

Standridge v. State, 357 Ark. 105 (Ark. 2004) (accomplice liability standards and corroboration requirements)
Taylor v. State, 370 S.W.3d 503 (Ark. 2011) (test for circumstantial evidence and accomplice connection)
Stephenson v. State, 282 S.W.3d 772 (Ark. 2008) (corroboration must tend to connect accused with crime)
Strong v. State, 277 S.W.3d 159 (Ark. 2008) (flight as corroborating factor)
Jordan v. State, 147 S.W.3d 691 (Ark. 2004) (intent in felony murder cases is to commit the felony, not the murder)
Dixon v. State, 385 S.W.3d 164 (Ark. 2011) (circumstantial evidence substantial when it excludes reasonable hypotheses)
Maxwell v. State, 285 S.W.3d 195 (Ark. 2008) (flight and corroboration in accomplice cases)
Perry v. State, 642 S.W.2d 865 (Ark. 1982) (contemporaneous objection rules for preservation)
Robinson v. State, 648 S.W.2d 444 (Ark. 1983) (rewarded consideration of sentencing disparity evidence)
Wicks v. State, 606 S.W.2d 366 (Ark. 1980) (exceptions to contemporaneous objection rule in death-penalty context)
Gillard v. State, 234 S.W.3d 310 (Ark. 2006) (standard for sufficiency review and corroboration)