Laswell v. State, 2012 Ark. 201

Laswell appeals a Benton County circuit court judgment convicting him of capital murder and aggravated robbery, sentenced as an habitual offender to life without parole plus 720 months.
Facts center on the August 30, 2007 arson/murder of Randy Walker and the subsequent police investigation.
Co-defendant Brandon Lacy admitted involvement; Lacy and Laswell described the events, including use of a weight bar to strike Walker and defile the scene.
Evidence included scene analysis, forensic testimony, and Laswell’s and Lacy’s interviews with investigators; weapons and items were recovered.
Laswell challenged the sufficiency of the evidence, the admission of certain prior-act evidence, the admissibility of crime-scene items, and the exclusion of Dr. Cunningham’s expert testimony.
The court affirmed, finding substantial evidence supporting guilt and no reversible error in evidentiary rulings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the evidence sufficient for capital murder and aggravated robbery?	Laswell argues insufficient evidence for in-course-and-furtherance and intent to rob.	Laswell contends the State failed to prove robbery and premeditated intent.	No error; substantial evidence supports convictions.
Was Queen’s testimony about Laswell’s prior acts properly admitted under Rule 404(b)?	Laswell argues Rule 404(b) exclusion due to bad acts evidence.	Laswell contends evidence is relevant to motive/intent and not improperly character evidence.	Admissible; evidence relevant to intent/motive; 404(b) curative instruction given.
Did the circuit court abuse its discretion regarding chain-of-custody objections to crime-scene items?	Laswell challenges authenticity and potential tampering of items.	Laswell alleges insufficient chain-of-custody, but State contends minor gaps not tainting authenticity.	No abuse of discretion; chain-of-custody sufficiently supported admission.
Was Dr. Cunningham’s expertise properly excluded from guilt phase testimony?	Laswell sought expert testimony on mental state affecting planning/intent.	Laswell argues Cunningham would illuminate intent and cognitive factors.	No abuse; testimony excluded as it would invade jury function and Stewart type ruling.

Smoak v. State, 2011 Ark. 529 (Ark. 2011) (sufficiency review standard for directed verdicts)
Sullivan v. State, 2012 Ark. 74 (Ark. 2012) (standard for weighing evidence and witness credibility)
Rounsaville v. State, 2009 Ark. 479 (Ark. 2009) (broad discretion in evidentiary rulings; Rule 404(b) analysis)
Stewart v. State, 316 Ark. 153 (Ark. 1994) (expert testimony on specific intent to murder and Rule 704 guidance)
DeGracia v. State, 321 Ark. 530 (Ark. 1995) (limits on expert testimony about intent and insanity distinctions)
Hinkston v. State, 340 Ark. 530 (Ark. 2000) (insanity defense framework and admissibility considerations)