Jesse Q. Collins v. State of Arkansas
2021 Ark. 35
Ark.2021Background
- On April 16, 2017, Jesse Q. Collins Jr. hosted a barbecue where he and guests drank; an earlier dispute with neighbors contributed to rising tensions.
- Collins retrieved a rifle after an argument with Bobby Moore, who had tried to prevent Collins from getting a gun.
- Collins shot Moore multiple times at very close range; Moore died from multiple gunshot wounds (some with soot rings indicating close-range firing).
- Collins then pointed the rifle at Jessica Gilbert and fired; the bullet grazed her ear/hair. Their three-year-old child was also the subject of an aggravated-assault charge.
- Collins waived Miranda and told police he fired because he thought Moore had a gun; other witnesses denied Moore had a weapon.
- A Hot Spring County jury convicted Collins of first-degree murder, attempted first-degree murder, and aggravated assault, imposed firearm and child-present enhancements, and sentenced him (habitual offender) to two consecutive life terms plus 55 years. Collins appealed, contesting the sufficiency of evidence of the required mental state (purpose) for the murder and attempted murder convictions.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Collins) | Held |
|---|---|---|---|
| Sufficiency of evidence that Collins acted purposely in killing Bobby Moore | Evidence (multiple close-range shots, manner of use, wounds, witness testimony) permits inference of purposeful intent | Collins argued intoxication and a belief Moore had a gun negated purposeful intent | Court: Substantial evidence supports first-degree murder; jury could infer purpose; voluntary intoxication does not negate intent |
| Sufficiency of evidence that Collins acted purposely in attempting to kill Jessica Gilbert | Gilbert’s testimony that Collins pointed and shot at her after killing Moore is a substantial step corroborating intent to kill | Collins argued intoxication impaired perception and that only one shot struck near Gilbert, so intent to kill is not proven | Court: Substantial evidence supports attempted first-degree murder; pointing and firing at close range is strongly corroborative of intent |
| Prejudicial-error review under Ark. Sup. Ct. Rule 4-3(a) | N/A | N/A | Court: Record reviewed; no prejudicial error found |
Key Cases Cited
- Price v. State, 588 S.W.3d 1 (2019) (standard for sufficiency-of-the-evidence review; view evidence in light most favorable to the State)
- Howard v. State, 506 S.W.3d 843 (2016) (circumstantial evidence may support conviction only if consistent with guilt and inconsistent with other reasonable conclusions)
- Armstrong v. State, 607 S.W.3d 491 (2020) (intent may form instantly; can be inferred from weapon, manner of use, and wound characteristics)
- Williams v. State, 468 S.W.3d 776 (2015) (witness credibility and conflicting testimony are for the jury to resolve)