Laron Hayes, Jr. v. State of Arkansas
2020 Ark. 297
Ark.2020Background
- December 26, 2017: Laron Hayes shot and killed Colby Rice and was later charged with first-degree murder, two counts of aggravated assault, and first-degree terroristic threatening; jury convicted April 25, 2019; sentence: life imprisonment + 15-year firearm enhancement for murder, consecutive terms/fines for other convictions.
- Eyewitness (Jeff Woodall): Rice tried to take Hayes’ keys, Hayes produced a pistol, returned it to the console, then on a second attempt shoved Rice out, pulled the pistol, said “Watch this, Woodall,” and shot Rice at contact range above the right eye.
- After the shooting Hayes chased Woodall pointing a pistol; he told several people (including by phone and to family) that he had killed Rice and threatened others; a recorded call to James Pope included repeated threats to kill Pope.
- Another eyewitness (Michael Tullos) saw Hayes retrieve a 12‑gauge shotgun and point it at him from ~100 yards; police found a jammed 9mm Glock and a loaded 12‑gauge with slugs in Hayes’ Jeep.
- Hayes gave a post‑arrest interview admitting he retrieved a gun and shot Rice but offered inconsistent reasons (claimed Rice had previously threatened him, referenced alcohol and prescription meds); no intoxication evidence was presented at the guilt phase.
- Procedural/result: Supreme Court reviewed sufficiency-of-the-evidence challenges, affirmed all convictions, but reversed and remanded to correct court costs to $150.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Hayes) | Held |
|---|---|---|---|
| Sufficiency of evidence for 1st‑degree murder (purpose) | Evidence (eyewitness account, contact wound, post‑shooting admissions/threats) supports an inference of purposeful killing. | Hayes claimed intoxication/medication and conflicting statements undermine a finding of purpose. | Affirmed: substantial evidence supports purpose; contact wound, manner of shooting, conduct after the shooting permitted the jury to infer intent. |
| Aggravated assault – Woodall (extreme indifference/purpose) | Running after Woodall pointing a pistol after shooting Rice created substantial risk under extreme indifference and showed purposeful conduct. | Hayes argued insufficient proof of extreme indifference or purposeful intent (no distance/time specifics). | Affirmed: jury could infer substantial danger and purpose from chasing Woodall with pistol aimed at him. |
| Aggravated assault – Tullos (substantial danger at ~100 yards) | Pointing a loaded 12‑gauge with slugs at Tullos and following him created substantial danger and manifested extreme indifference. | Hayes argued a shotgun at ~100 yards could not create substantial risk to Tullos. | Affirmed: pointing a loaded 12‑gauge at Tullos, plus following, supported finding of substantial danger and intent. |
| First‑degree terroristic threatening – Pope (purpose to terrorize) | Recorded phone threats to kill Pope and repeated location‑seeking showed a purpose to terrorize. | Hayes contended the call sought to force a conversation, not to terrorize. | Affirmed: recorded threats and context supported jury inference of purposeful terrorizing threats. |
| Court costs amount | State noted circuit court assessed $165 but statute fixes uniform costs at $150. | — | Reversed in part: remanded to amend sentencing order to assess $150 in court costs. |
Key Cases Cited
- Reynolds v. State, 2016 Ark. 214, 492 S.W.3d 491 (standard for reviewing sufficiency of the evidence)
- Carey v. State, 365 Ark. 379, 230 S.W.3d 553 (strict preservation requirement for directed‑verdict motions)
- Perry v. State, 2014 Ark. 535, 453 S.W.3d 650 (general directed‑verdict motion insufficient to preserve specific sufficiency challenges)
- Tarentino v. State, 302 Ark. 55, 786 S.W.2d 584 (purpose to commit a crime can form instantly)
- Starling v. State, 301 Ark. 603, 786 S.W.2d 114 (intent usually inferred from circumstances)
- Garza v. State, 293 Ark. 175, 735 S.W.2d 702 (type and manner of weapon use support inference of intent)
- Harmon v. State, 340 Ark. 18, 8 S.W.3d 472 (presumption that actors intend natural and probable consequences; use of common knowledge to infer intent)
- Dillehay v. State, 74 Ark. App. 100, 46 S.W.3d 545 (pointing a gun can support aggravated‑assault conviction)
- Leaks v. State, 345 Ark. 182, 45 S.W.3d 363 (only evidence supporting the verdict is considered on appeal)
- Bilderback v. State, 319 Ark. 643, 893 S.W.2d 780 (review of illegal sentence issues in life‑imprisonment cases)