Procella v. State, 2016 Ark. App. 515

Jeffery Duane Procella was convicted by a Miller County jury of two counts of theft of scrap metal and two counts of first-degree criminal mischief and sentenced to an aggregate 12 years.
Union Pacific signal maintainers discovered signal shunt wire repeatedly cut and removed at a Pinehurst Street crossing on April 14, 18, and 19, 2015; each theft removed ~25–30 feet of wire and caused about $800 in damage per incident.
Motion-activated camera captured a white male (Procella) and a white female (Amy Telles) near the shunt wire; photos showed the wire present in one frame and missing in the next.
Procella admitted being on the tracks on April 18 and 19 and admitted picking up wire he claimed was lying on the ground; Telles testified Procella cut, rolled, and concealed the shunt wire in their backpacks.
Procella moved for directed verdicts arguing insufficient corroboration of accomplice (Telles) testimony; the jury was instructed that accomplice testimony required corroboration for the felonies (though two counts were reduced to misdemeanors).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of corroboration for accomplice testimony	State: circumstantial evidence (photos, admissions, timing, cessation of thefts) corroborates Telles and connects Procella to the thefts	Procella: photos do not show cutting or concealing; no wire/clippers/receipts found; other people were in area—evidence only raises suspicion	Court: corroboration was substantial; circumstantial evidence independently tended to connect Procella with the crimes; convictions affirmed

Smith v. State, 423 S.W.3d 624 (Ark. Ct. App. 2012) (accomplice testimony must be corroborated by evidence that independently connects defendant to crime)
Riley v. State, 343 S.W.3d 327 (Ark. Ct. App. 2009) (corroborating evidence may be circumstantial but must be more than mere suspicion)