Pearcy v. State
2010 Ark. 454
| Ark. | 2010Background
- Pearcy was convicted of premeditated capital murder and sentenced to life without parole.
- Police observed Pearcy acting suspiciously; he confessed to a murder and was taken to the station.
- Pearcy provided a detailed, self-serving confession alleging he killed Stacy Lewis for curiosity and to see if he could get away with it.
- Medical examiner found Lewis had multiple stab wounds and signs of defensive wounds, with body placed in a trash can for weeks.
- Searches of Pearcy’s apartment recovered the knife and bloodstain evidence; body later transported for autopsy.
- Pearcy argued on appeal that the evidence was insufficient for premeditation and that certain photos should have been excluded; the court affirmed the conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Premeditation and deliberation sufficiency | Pearcy claims lack of premeditation; mental disease/defect defense not preserved. | State asserts circumstantial evidence supports premeditation. | Sufficient evidence supports premeditation; conviction affirmed. |
| Admissibility of photographs (Exhibits 11 and 45) | Not preserved or objection-specific; alleged prejudicial impact. | Photos are admissible to explain testimony and illustrate conditions. | Preservation lacking; even if preserved, no reversible error. |
Key Cases Cited
- Winston v. State, 269 S.W.3d 809 (Ark. 2007) (premeditation may be inferred from circumstantial evidence)
- Robinson v. State, 214 S.W.3d 840 (Ark. 2005) (circumstantial proof of premeditation and deliberation)
- Marcyniuk v. State, 373 S.W.3d 243 (Ark. 2010) (preservation of insanity defense requires specific directed-verdict basis)
- Rounsaville v. State, 273 S.W.3d 486 (Ark. 2008) (sufficiency challenge requires specific grounds at trial)
- Tester v. State, 30 S.W.3d 99 (Ark. 2000) (insanity-defense preservation standards)
- Brown v. State, 875 S.W.2d 828 (Ark. 1994) (insanity defense preservation principles)
- Blanchard v. State, 321 S.W.3d 250 (Ark. 2009) (preservation and specificity of objections on appeal)
- Weger v. State, 869 S.W.2d 688 (Ark. 1994) (admissibility of photographs; purpose and prejudicial impact)
- Berry v. State, 718 S.W.2d 447 (Ark. 1986) (photographs admissible if they aid proof; not inadmissible merely for being cumulative)
- Gruzen v. State, 591 S.W.2d 342 (Ark. 1979) (gruesome photographs admissible to show wounds or show premeditation)
- Perry v. State, 500 S.W.2d 387 (Ark. 1973) (admissibility of photos to rebut self-defense claims or show injuries)
- Jones v. State, 10 S.W.3d 449 (Ark. 2000) (photographs showing condition and location of injuries)
- Ray v. State, 357 S.W.3d 872 (Ark. 2009) (preservation and appellate review standards)