Spearman v. State, 2013 Ark. 196

Spearman was found guilty by a jury of two counts of aggravated robbery and one count of theft of property, receiving life sentences on the aggravated-robbery convictions and 20 years on the theft conviction as a habitual offender.
On appeal, Spearman challenges the sufficiency of the evidence to prove his identity and the denial of a directed verdict.
Spearman also challenges the State’s compliance with the Interstate Agreement on Detainers Act (IADA) and extradition procedures, seeking dismissal of the information.
Jones identified Spearman in court and in two photographic lineups—before and after he wore glasses—describing a bandana, red hat with a white “W,” and a silver pistol; description matched surveillance video.
Law enforcement recovered from Spearman’s residence a blue/black bandana, a red “W” hat, and a pistol with a black handle and a silver barrel, and Spearman was found in a vehicle matching one seen near the store.
The court affirmed, holding substantial evidence supported the verdicts and that the record did not prove IADA extradition violations for relief; the IADA issue was deemed non-meritorious for other reasons when applicable; no prejudicial error found under Rule 4-3(i).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the evidence was sufficient to identify Spearman as the perpetrator	Spearman	State	No; substantial evidence supports identification
Whether the State complied with IADA/extradition and whether dismissal was warranted	Spearman	State	IADA not shown to apply; no reversal for extradition issues

Lacy v. State, 377 S.W.3d 227 (Ark. 2010) (substantial-evidence standard for sufficiency review)
Lockhart v. State, 367 S.W.3d 530 (Ark. 2010) (sufficiency-review framework; view evidence in the light most favorable to the verdict)
Smith v. State, 528 S.W.2d 359 (Ark. 1975) (IADA applicability when sending state not a party)
Young v. State, 491 S.W.2d 789 (Ark. 1973) (180-day timing not applicable when sending state not a party)