Evans v. State
2011 Ark. 33
| Ark. | 2011Background
- Evans was convicted of capital murder and a firearm enhancement, and sentenced to life without parole, though the judgment did not reflect the enhancement or habitual offender status.
- The homicide occurred on October 8, 2008, when Deshon Pride was shot and found dead in a Wrightsville, Arkansas living room.
- Evans turned himself in to police the morning after the shooting and was charged in an amended information filed July 31, 2009.
- A jury found Evans guilty of capital murder and the firearm enhancement but acquitted him on two counts of intimidating a witness.
- The defense challenged the sufficiency of the evidence supporting the capital-murder conviction, arguing inconsistencies and lack of credible proof tying Evans to the killing.
- On appeal, the court applied the standard for substantial evidence and affirmed the conviction and sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the evidence is sufficient for capital murder | Evans argues insufficient evidence to prove premeditated murder. | State contends substantial evidence supports guilt beyond speculation. | Evidence is substantial; conviction affirmed. |
Key Cases Cited
- Johnson v. State, 375 Ark. 462 (2009) (directed-verdict standard and sufficiency review)
- Hoyle v. State, 371 Ark. 495 (2007) (premeditation inference from circumstances)
- Marcyniuk v. State, 2010 Ark. 257 (2010) (circumstantial evidence must be consistent with guilt)
- Clemons v. State, 2010 Ark. 337 (2010) (credibility of witnesses is for the jury)
- Rounsaville v. State, 2009 Ark. 479 (2009) (jury credibility assessments)
- Wyles v. State, 368 Ark. 646 (2007) (consistency of evidence with verdict; weighing testimony)
- Davenport v. State, 373 Ark. 71 (2008) (review of witness testimony and defenses)
- Carmichael v. State, 12 S.W.3d 225 (2000) (premeditation and deliberation may be inferred from circumstances)
