Noble v. State, 2017 Ark. 142

In Feb. 2014 Willie Noble fired multiple shots at a car occupied by teenagers after they toilet-papered and egged property; Adrian Broadway (front passenger) was killed by a shot.
Noble was tried in Pulaski County and convicted by a jury of first-degree murder (felony murder), six counts of terroristic acts (shooting at an occupied vehicle to cause property damage or injury), and related firearm enhancements.
Sentences: 240 months for first-degree murder + 120 months consecutive for firearm use; fines for terroristic acts and concurrent firearm terms on those counts.
Noble moved for directed verdicts on all charges, arguing insufficient evidence of (1) intent to cause property damage for terroristic-act counts and (2) that Broadway’s death occurred "in furtherance of" the terroristic acts required for felony murder.
The circuit court denied the motions; on appeal the Arkansas Supreme Court reviewed sufficiency-of-the-evidence de novo (viewing evidence in the light most favorable to the State).
The majority affirmed, finding (a) evidence supported an inference Noble intended to damage the vehicle and (b) Broadway’s death occurred in the course of and in furtherance of the terroristic acts; a concurring/dissent argued the majority misapplied the statutory “furtherance” element.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for terroristic-act convictions (intent to cause property damage)	State: eyewitness testimony and physical damage support an inference Noble intended to damage the vehicle.	Noble: he said he only fired to scare them; no direct proof he intended property damage.	Affirmed — jury could infer intent to cause property damage from multiple aimed shots and resulting vehicle damage.
Whether Broadway’s death was "in the course of and in furtherance of" the terroristic acts (felony-murder)	State: Noble had an independent objective (terroristic acts) and the killing occurred in the course of and furthered that felony.	Noble: the killing did not "facilitate" the terroristic acts; murder was not committed to accomplish the felony (relying on Parker/Craig).	Affirmed — majority concluded substantial evidence showed the death occurred in course of and in furtherance of the terroristic acts; concurrence/dissent disagreed, arguing "furtherance" requires facilitation.

Kinsey v. State, 503 S.W.3d 772 (2016) (standard for sufficiency review; view evidence in light most favorable to State)
Rollins v. State, 347 S.W.3d 20 (2009) (intent often inferred from circumstances; juries may rely on common knowledge)
Davis v. State, 348 S.W.3d 553 (2009) (presumption that persons intend natural and probable consequences of their acts)
Parker v. State, 731 S.W.2d 756 (1987) (felony-murder requires underlying felony to have an independent objective that the murder facilitates)
Craig v. State, 14 S.W.3d 893 (2000) (assaults done in furtherance of homicide, not an independent felony, do not support felony murder)
Perry v. State, 264 S.W.3d 498 (2007) (mens rea for felony murder relates to underlying felony, not the murder)
Sellers v. State, 749 S.W.2d 669 (1988) (interpreting “furtherance” in felony-murder context)
Allen v. State, 751 S.W.2d 347 (1988) (example where murder facilitated the underlying felony—burglary to steal—and supports felony-murder)