Satterfield v. State
2014 Ark. App. 633
Ark. Ct. App.2014Background
- Appellant was charged with first-degree murder and tried by jury; found not guilty of first-degree murder but guilty of second-degree murder.
- Appeal questions sufficiency of evidence for knowingly killing the victim; circumstantial evidence presented.
- Court reviews sufficiency using the standard that circumstantial evidence is adequate if it excludes every other reasonable hypothesis.
- Facts show appellant threatened the victim with a gun, spoke about drugs on credit, fired, and the victim died instantly; body wrapped and placed in appellant’s truck.
- Gun could not fire unless cocked and pressed with four pounds of pressure; wound described as a shot to the eye from six to eight inches.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the evidence sufficient to prove knowingly killed the victim? | Satterfield argues the evidence is circumstantial and equally supports recklessness. | State contends the circumstances, threat, concealment, wound, and firearm characteristics negate mere speculation. | Yes; substantial evidence supports knowingly killing. |
Key Cases Cited
- Garner v. State, 2013 Ark. App. 250 (Ark. App. 2013) (circumstantial evidence may be sufficient if it excludes innocence)
- Simpkins v. State, 2010 Ark. App. 723 (Ark. App. 2010) (standard to assess sufficiency and weight of evidence)
- Ridling v. State, 360 Ark. 424, 203 S.W.3d 63 (2005) (fact-finder credibility and conflicts are for the trial court and reviewing court)
- Williams v. State, 325 Ark. 432, 930 S.W.2d 297 (1996) (limits on reviewing circumstantial evidence and weight of testimony)
- Davis v. State, 2009 Ark. 478, 348 S.W.3d 553 (2009) (intent inferred from circumstances when direct evidence lacking)
- Copeland v. State, 343 Ark. 327, 37 S.W.3d 567 (2001) (consideration of weapon, manner, wounds in proving intent)
- Fudge v. State, 341 Ark. 759, 20 S.W.3d 315 (2000) (circumstances surrounding crime support inference of intent)
- Crawford v. State, 309 Ark. 54, 827 S.W.2d 134 (1992) (conduct after crime relevant to consciousness of guilt)