James E. Pearson v. State, 389 P.3d 794

Defendant James E. Pearson was tried by jury for aggravated arson and attempted first‑degree murder for setting a gasoline‑accelerated fire in the hallway outside Room 315 of a motel where victim Autumn Evans was staying; others were injured and escape routes were blocked.
Surveillance, gas receipt, a burned fuel can recovered outside Room 315, accelerant detection, and cell‑phone/patrol video placed a distinctive car matching Pearson’s near the motel shortly before the fire; Pearson left town just before the fire was reported.
Pearson admitted (and the jury found) he set the fire (a substantial step), but disputed that the State proved the specific intent to kill Evans.
On the Friday before trial the State granted immunity and disclosed a plea arrangement with witness Cameron Means; defense counsel was told of those agreements early the first trial day and cross‑examination opportunity existed.
Jury convicted on both counts; Pearson received an aggregate lengthy prison term and appealed, arguing insufficiency of evidence on specific intent and a Brady/Giglio due process violation from late disclosure of witness agreements.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for attempted 1st‑degree murder	Pearson: setting the fire (the overt act) cannot be used to prove specific intent to kill; insufficient proof of intent to kill Evans	State: intent to kill may be inferred from the character of the act and surrounding circumstances (arson outside occupied room at night, blocked egress, motive, flight)	Court affirmed conviction: jury reasonably could infer specific intent from the totality of circumstances including the arson and context
Late disclosure of witness immunity/plea agreements (Brady/Giglio)	Pearson: State’s late disclosure of immunity/plea deals with Means deprived him of due process and impaired trial preparation/impeachment	State: agreements were disclosed before trial began and defense had opportunity to use them at trial; no suppression under Brady/Giglio/Bagley	Court held no Brady/Giglio violation because disclosure occurred before trial use and defense had opportunity to impeach; no due process violation

Elfbrandt v. Russell, 397 P.2d 944 (Ariz. 1964) (discusses need to prove specific intent separate from overt act)
Brady v. Maryland, 373 U.S. 83 (1963) (prosecution must disclose favorable, material evidence)
Giglio v. United States, 405 U.S. 150 (1972) (impeachment agreements with witnesses must be disclosed)
United States v. Bagley, 473 U.S. 667 (1985) (materiality standard for undisclosed impeachment evidence)
Garcia v. State, 777 P.2d 1091 (Wyo. 1989) (specific intent proven by circumstantial evidence and inferences)