Brooks v. State, 2016 Ark. 305

Victim Amy Mae Hughett was found partially burned in a storage building; autopsy showed blunt-force trauma, strangulation, and numerous facial/head injuries; cause of death blunt-force trauma and strangulation.
Fire debris and Hughett’s clothing tested positive for gasoline; tires and plastic tubing were placed over her body.
DNA matching Brooks was recovered from vaginal swabs; blood matching Hughett’s was found on the front passenger seat of a Jeep Brooks had used; the Jeep smelled of gasoline.
Witnesses placed Brooks in the vicinity the morning Hughett’s body was found; one witness (Clemmons) testified Brooks confessed; family testified Brooks left in the Jeep and the vehicle smelled of fumes.
Brooks admitted recent sexual contact with Hughett but denied killing her, offering an alternative account that a passenger had bloody clothes; he also testified the Jeep smelled of gasoline when he entered it that morning.
Procedural posture: Jury convicted Brooks of capital murder and abuse of a corpse; he received life without parole and thirty years; he appealed claiming insufficiency of evidence to prove killing and premeditation/deliberation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to prove Brooks killed Hughett	State: circumstantial evidence (DNA, blood in vehicle, gasoline, location, confession) supports that Brooks was the killer	Brooks: evidence does not establish he committed the murder; alternative actor suggested	Court: Affirmed—substantial circumstantial evidence supports that Brooks committed the murder
Whether evidence established premeditation and deliberation for capital murder	State: multiple blows, prolonged violent struggle, strangulation (requires minutes), and attempts to destroy evidence support premeditation	Brooks: no proof he formed intent to kill before acting; lack of direct evidence of planning	Court: Affirmed—jury reasonably inferred premeditation and deliberation from nature/extent/location of injuries and conduct

Starling v. State, 480 Ark. 158 (standard for treating directed-verdict challenge as sufficiency review)
Sylvester v. State, 489 S.W.3d 146 (substantial-evidence definition)
Mercouri v. State, 480 S.W.3d 864 (viewing evidence in light most favorable to State on sufficiency review)
Williams v. State, 385 S.W.3d 157 (definition of premeditation and deliberation)
Carmichael v. State, 340 Ark. 598 (premeditation may be formed in an instant)
Pearcy v. State, 375 S.W.3d 622 (premeditation usually inferred from circumstances)
Green v. State, 430 S.W.3d 729 (jury may infer premeditation from type/character of weapon, wounds, and conduct)
Gill v. State, 474 S.W.3d 77 (circumstantial evidence must exclude every other reasonable hypothesis to be substantial)
Conte v. State, 463 S.W.3d 686 (whether evidence excludes other reasonable hypotheses is for the jury)
McKenzie v. State, 208 S.W.3d 173 (jury is sole judge of witness credibility and may reject defendant’s self-serving testimony)