Leach v. State
2012 Ark. 179
| Ark. | 2012Background
- Leach III was convicted of capital murder and sentenced to life without parole;affirmed on appeal under Ark. Sup. Ct. Rule 1-2(a)(2).
- Event occurred July 17, 2009, at about 3:00 a.m. in Cove, Arkansas; Casey was stabbed in the truck with three other witnesses present and accusing Leach.
- Jack Shepard testified that Leach and Prine were intoxicated; Leach admitted stabbing Casey and they discussed getting rid of the body; a knife was tossed into the truck toolbox.
- Tyler Prine testified Leach stabbed Casey after a fight; knife recovered in toolbox; blood on knife matched Casey; Prine’s testimony supported the State’s narrative.
- Forensic and medical evidence showed Casey died from multiple stab wounds consistent with the recovered knife; DNA linked Casey’s blood to the knife and to Leach’s clothing.
- Appellant challenged five trial rulings on appeal: directed verdict, suppression of statement, Rule 404(b)(relevancy), Rule 608(cross-exam), and officer’s opinion testimony; all issues were appealed and ultimately affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Directed verdict sufficiency | Leach argues insufficient evidence of premeditated murder and causation. | State failed to prove premeditation, deliberation, and causation due to intoxication and lack of evidence. | Sufficient evidence supports premiditation and causation; verdict affirmed. |
| Rule 608 cross-examination | Leach should be allowed to question Prine about threats to another witness under Rule 608(b). | Extrinsic questioning about conduct is not allowed; threats evidence is improper without foundation. | Issue not preserved due to lack of proper proffer; cross-examination limited by Rule 608; affirmed denial. |
| Suppression | Custodial statement was involuntary and obtained in violation of Miranda; fruits should be suppressed. | Statement was voluntarily given; Miranda waiver valid; delays sober the suspect; no coercion. | Waiver voluntary; not clearly against the preponderance; suppression denied. |
| Rule 404(b)/Relevancy | Video includes reference to a child-molester claim; DHS matters should be redacted to avoid prejudice. | Redaction necessary to avoid prejudice; 404(b) evidence should be limited. | Issue not preserved; no proper Rule 404(b) objection or ruling; affirmed evidentiary ruling. |
| Officer testimony (Rule 701/602) | Agent’s lay opinion that Leach had blood on his hand was speculative and improper. | Testimony was rational, based on perception, and helpful to understanding the scene. | Experienced officer testimony properly admitted; no abuse of discretion. |
Key Cases Cited
- Evans v. State, 378 S.W.3d 82 (Ark. 2011) (premeditation may be inferred from circumstances)
- Carmichael v. State, 12 S.W.3d 225 (Ark. 2000) (premeditation not required for a fixed time; may be instant)
- Pearcy v. State, 375 S.W.3d 622 (Ark. 2010) (premeditation inferred from circumstances and weapon use)
- Robinson v. State, 214 S.W.3d 840 (Ark. 2005) (circumstantial evidence may establish premeditation/deliberation)
- White v. State, 717 S.W.2d 784 (Ark. 1986) (voluntary intoxication not an affirmative defense)
- Halford v. State, 27 S.W.3d 346 (Ark. 2000) (preservation requires proffer of anticipated testimony)
- Flowers v. State, 208 S.W.3d 113 (Ark. 2005) (courts review voluntariness and totality of circumstances in confessions)