Meadows v. State
2012 Ark. 57
| Ark. | 2012Background
- Meadows was convicted in Union County Circuit Court of capital murder, residential burglary, and theft of property; sentenced to life without parole for capital murder and additional terms for burglary and theft.
- The State relied on Meadows' out-of-court confession, an accomplice’s testimony from Marquita Meeks, physical/forensic evidence, and a video still from Hardy Mart to prove guilt.
- Meadows argued the State failed to independently corroborate his confession and the accomplice’s testimony, and that overlapping murder statutes were unconstitutionally vague.
- The jury found Meadows guilty after severance from codefendant Victor Meadows; the court instructed on capital murder and lesser-included offenses.
- A pretrial and ongoing post-trial record raised issues about confessions, accomplice corroboration, and the alleged vagueness of statutes; the trial court did not rule on the new-trial motion, which was deemed denied, and the appeal followed.
- The appellate court affirmed, holding sufficient corroboration exists for the confession even without independent evidence, and that preservation issues foreclose review of the vagueness claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Corroboration of confession and accomplice testimony | Meadows argues insufficient corroboration for confession and for accomplice Meeks' testimony. | Meadows contends the State must independently connect him to the crime beyond the confession and accomplice. | No independent corroboration needed; confession suffices to corroborate accomplice testimony. |
| Vagueness of capital murder and first-degree murder statutes | Statutes are unconstitutionally vague and confusing due to overlap. | Statutory overlap has been previously rejected; foreman’s affidavit shows confusion but nothing changes law. | Not preserved for appeal; statutes are not unconstitutionally vague as applied here. |
| Preservation of jury-confusion objections and Rule 606(b) | Foreman’s affidavit shows juror confusion; objections should be reviewable. | Rule 606(b) bars consideration of juror deliberations; late objections. | Not preserved; review declined. |
Key Cases Cited
- Booe v. State, 188 Ark. 774 (1934) (confession can corroborate accomplice testimony)
- Knowles v. State, 113 Ark. 257 (1914) (confession can corroborate offense occurrence)
- Johnson v. State, 358 Ark. 460 (2004) (no need for independent evidence to corroborate confession)
- Ventry v. State, 2009 Ark. 300 (2009) (corpus delicti corroboration concept)
- Ware v. State, 348 Ark. 181 (2002) (corpus delicti and confession corroboration framework)
- Tinsley v. State, 338 Ark. 342 (1999) (confession corroboration standards)
- Hall v. State, 361 Ark. 379 (2005) (corroboration and connection to crime)
- Hart v. State, 301 Ark. 200 (1990) (elements of corpus delicti)
- Camp v. State, 2011 Ark. 155 (2011) (accomplice corroboration standards)
- MacKool v. State, 365 Ark. 416 (2006) (indirect corroboration suffices to connect defendant)
- Parker v. State, 355 Ark. 639 (2004) (consideration of accomplice connection factors)
- Andrews v. State, 344 Ark. 606 (2001) (joint participation and liability principles)
- Rockett v. State, 319 Ark. 335 (1995) (preservation of objections by codefendant)
- Smith v. State, 308 Ark. 603 (1992) (procedural preservation principles)
- Zinger v. State, 313 Ark. 70 (1993) (timeliness of jury instruction objections)
- Tosh v. State, 278 Ark. 377 (1983) (timeliness of objections to instructions)
- Brown v. State, 277 Ark. 294 (1982) (instruction-objection timing)
- Flowers v. State, 362 Ark. 193 (2005) (overlapping murder statute precedent)
- Williams v. State, 346 Ark. 54 (2001) (overlap volatility of statutes)
- Sanders v. State, 317 Ark. 328 (1994) (overlapping elements in murder statutes)
- Cromwell v. State, 269 Ark. 104 (1980) (statutory construction in murder cases)