Lawshea v. State, 567 S.W.3d 853

On Nov. 5, 2016, Avante Lawshea, with Christopher Clay, Ledarrius Simmons, and driver Issac Branch, traveled in Branch’s distinctive white 1994 Chevrolet station wagon and were observed on hotel and gas-station surveillance footage.
The three men left Branch’s car, attempted to enter a locked Shell station, then proceeded to Bob’s Cherry Tree station; surveillance showed three masked men (one in red, two in darker colors).
Inside Cherry Tree, the man in red (identified at trial as Lawshea) demanded money and shot owner Bahadur “Bob” Dhillon in the neck and employee Anthony Tramble in the face; both died. A child was present in the store.
After gunshots, witnesses saw multiple men run to Branch’s parked station wagon and drive away; Branch later admitted giving the men a ride that evening.
Investigators recovered a cigarette butt from Branch’s car containing Lawshea’s DNA; Jaleesa Harris and others identified Lawshea with the group earlier that night.
Lawshea was tried as an accomplice to aggravated robbery leading to capital-felony murder, convicted on two counts of capital murder and one count of aggravated robbery, and sentenced to life terms (each with a ten-year child-presence enhancement) plus ten years for robbery. Appeal challenges sufficiency/corroboration of accomplice testimony.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence/corroboration for accomplice testimony	Lawshea: accomplice (Branch) testimony was uncorroborated and insufficient to support convictions	State: surveillance, eyewitness identifications, cigarette DNA, and other testimony corroborate and connect Lawshea to the crimes	Affirmed — substantial circumstantial and corroborating evidence connected Lawshea to the robbery and murders; jury could infer guilt
Whether circumstantial evidence can sustain conviction	Lawshea: circumstantial proof here is inadequate to exclude other reasonable hypotheses	State: circumstantial evidence may be sufficient if consistent with guilt and inconsistent with innocence	Court: circumstantial evidence may sustain conviction; here it was substantial and properly left to jury
Proper application of accomplice-liability theory	Lawshea: challenges being held liable as accomplice absent sufficient corroboration	State: accomplice liability applies where persons assist one another; corroboration requirement met	Court: accomplice-liability standard met; corroborating evidence tended to connect Lawshea to crimes independent of Branch’s testimony
Directed verdict standard / review for reversible error	Lawshea: trial court should have granted directed verdict for insufficiency	State: evidence supports denying directed verdict	Court: reviewed in light most favorable to verdict, found no reversible error and denied directed-verdict claim

Williams v. State, 2017 Ark. 287, 528 S.W.3d 839 (discussing sufficiency review standards)
Tarver v. State, 2018 Ark. 202, 547 S.W.3d 689 (standard for assessing sufficiency and substantial evidence)
Conway v. State, 2016 Ark. 7, 479 S.W.3d 1 (accomplice-liability review)
Howard v. State, 2016 Ark. 434, 506 S.W.3d 843 (circumstantial-evidence sufficiency principles)
Gardner v. State, 364 Ark. 506, 221 S.W.3d 339 (corroboration of accomplice testimony may be satisfied by circumstantial evidence)
Bradley v. State, 2013 Ark. 58, 426 S.W.3d 363 (corroborating evidence must tend to connect accused to the crime independent of accomplice testimony)