Crista Ann Steadmon v. State of Arkansas
2024 Ark. App. 586
Ark. Ct. App.2024Background
- Crista Ann Steadmon was convicted by an Ashley County jury of possession of a firearm by certain persons (a felon in possession), a Class B felony under Arkansas law, and sentenced as a habitual offender to eight years' incarceration and a $7,000 fine.
- The conviction stemmed from a May 11, 2023, welfare check at a residence where Steadmon was located in a locked wood shop; operable firearms were found in the residence, including one in the room where she was found.
- Law enforcement conducted a search of the premises based on Steadmon’s probation search waiver and the fact that her driver’s license listed the home as her address.
- Steadmon and her associates (mother and boyfriend, O’Neal) gave conflicting testimony regarding her residence and access to the firearms.
- The main dispute at trial and on appeal was whether Steadmon constructively possessed the firearm found near her, as opposed to merely being present near it.
Issues
| Issue | Steadmon's Argument | State's Argument | Held |
|---|---|---|---|
| Sufficiency of Evidence | No evidence of actual or constructive possession, | Constructive possession shown by close proximity | Substantial evidence supports constructive |
| of Possession | no proof she lived there or had control. | of firearm, proximity, and listing on documents. | possession; conviction affirmed. |
| Constructive Possession | No other factors link her to firearm except presence | Residency, location near her, listed residence. | Mere proximity sufficient; other factors present. |
| Residency as Linking Fact | She did not reside in the home at the relevant time | Address on ID and waiver, use of residence. | Evidence supports finding of residence. |
Key Cases Cited
- Kelley v. State, 286 S.W.3d 746 (Ark. Ct. App. 2008) (sets standard of review for sufficiency of evidence and role of jury)
- Dunn v. State, 264 S.W.3d 504 (Ark. 2007) (jury's authority to resolve conflicting testimony)
- Holcomb v. State, 432 S.W.3d 600 (Ark. 2014) (considering only evidence supporting the verdict on appeal)
- Robinson v. State, 491 S.W.3d 481 (Ark. Ct. App. 2016) (circumstantial evidence can support conviction if inconsistent with any reasonable explanation other than guilt)