Dees v. State, 126 So. 3d 21

Dees was convicted of first-degree arson and insurance fraud in the Tippah County Circuit Court; arson sentence: 10 years with 2 to serve, 8 suspended, 3 years post-release supervision; insurance-fraud sentence: 2 years, concurrent.
January 2008: Dees claimed theft on Farm Bureau homeowner’s policy and was reimbursed $7,480.24 for losses from burglary.
October 6, 2008: a fire at Dees’s residence caused extensive damage; the fire investigation concluded incendiary origin after Farm Bureau’s electrical engineer ruled out electrical cause.
Lay and expert testimony disputed cause: some witnesses suggested electrical problems; others supported incendiary origin; investigators found ignitable liquids and patterns suggesting arson.
Evidence linked to insurance-fraud claim: items reported stolen later appeared in the home or in Dees’s son’s possession; Dees gave inconsistent explanations about recovered items.
Dees argued sufficiency of the evidence but the court held the circumstantial evidence was sufficient to support both convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the arson conviction supported by sufficient evidence?	Dees contends the fire had an electrical cause with reasonable innocence hypothesis.	Dees argues the evidence allows an electrical explanation; arson not proven willfully and maliciously.	Yes; circumstantial evidence supported willful arson beyond a reasonable doubt.
Was the insurance-fraud conviction supported by sufficient evidence under §7-5-303(2)(a)?	State contends the policy qualifies as an insurance plan with health benefits, and fraud occurred under the statute.	Dees argues the Farm Bureau homeowners policy is not an insurance plan under the statute because it does not provide health benefits.	Yes; policy provided $1,000 medical benefits, so the plan fits the definition and evidence showed defrauding the plan.

Shumpert v. State, 935 So.2d 962 (Miss.2006) (standard for sufficiency review on appeal)
Bush v. State, 895 So.2d 836 (Miss.2005) (reiterates Jackson v. Virginia standard)
Carr v. State, 208 So.2d 886 (Miss.1968) (evidence sufficiency framework)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for reasonable-doubt in criminal conviction review)
Edwards v. State, 469 So.2d 68 (Miss.1985) (lends framework for evaluating circumstantial evidence)
Hughes v. State, 90 So.3d 613 (Miss.2012) (circumstantial evidence sufficiency and reasonable-doubt standard)