Keith Jeffery Wofford v. State of Arkansas
675 S.W.3d 137
Ark.2023Background
- On December 26, 2020, Keith Wofford stabbed his ex-wife, Amber Cooksey, forty‑five times; wounds included multiple head, neck, chest, and hand stab wounds. Two neck wounds severed the right carotid artery and jugular vein.
- Police found Cooksey’s groceries undisturbed in her car; Wofford called 911 confessing and alleging Cooksey’s illicit conduct and claiming memory gaps. He showered and changed clothes after the killing.
- Wofford admitted the killing at trial but asserted an involuntary‑intoxication affirmative defense tied to his prescription Wellbutrin (he had occasionally taken higher than prescribed doses).
- Defense presented testimony that Wellbutrin can, in rare cases, cause paranoid or homicidal thoughts; the pharmacist lacked specifics about Wofford’s exact usage.
- The jury rejected the intoxication defense, convicted Wofford of capital murder (premeditated and deliberated purpose), and sentenced him to life imprisonment; Wofford appealed on sufficiency grounds.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for capital murder (premeditation/deliberation) | State: multiple, forceful stab wounds (45), wounds inflicted while victim alive, carotid/jugular severed twice, show premeditation | Wofford: claimed memory loss, lack of intent, no effort to conceal the crime | Affirmed — substantial evidence supports conviction; jury credited State; premeditation/deliberation found |
| Validity of involuntary‑intoxication defense | State: evidence did not prove involuntary intoxication or loss of culpable mental state | Wofford: Wellbutrin use/overdose caused involuntary intoxication negating intent | Held — jury rejected the defense; court will not second‑guess credibility determinations |
| Appellate review under Ark. Sup. Ct. R. 4‑3(a) | State: life sentence lawful; record supports conviction | Wofford: asserted errors warrant reversal | Held — full record review found no reversible error; sentence affirmed |
Key Cases Cited
- Collins v. State, 617 S.W.3d 701 (Ark. 2021) (standard for reviewing sufficiency of the evidence on appeal)
- Fudge v. State, 20 S.W.3d 315 (Ark. 2000) (multiple stab wounds can indicate premeditation and deliberation)
- Dunn v. State, 264 S.W.3d 504 (Ark. 2007) (jury resolves witness credibility and conflicting evidence)