Starling v. State, 468 S.W.3d 294

Starling was convicted on August 20, 2014, after a three-day jury trial in Miller County Circuit Court of murder in the first degree and committing a terroristic act, with firearm enhancements, and was sentenced to 110 years.
Starling appeals asserting there is insufficient evidence of the conscious object required for the first-degree murder and the terroristic act.
April 18, 2013, Demetria Satterwhite arranged meeting about drugs; Hawkins took Starling’s crack cocaine in P.J.’s car and left without paying.
Starling gathered his brother Serandan and others, threatened Satterwhite, and helped hunt for Hawkins and P.J., driving around with a gun on his lap.
P.J. was shot and killed by Serandan; Starling’s group buried weapons and burned their clothes; Starling admitted involvement in drug dealing and lied to detectives; the evidence linked him to the conspiracy and pursuit of the crime.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there is substantial evidence of conscious object for murder/terroristic act	Starling argues insufficient proof of conscious object	State contends accomplice theory shows conscious object	Yes; substantial evidence supports conscious object

Green v. State, 430 S.W.3d 729 (Ark. 2013) (accomplice liability for joint criminal acts)
Clark v. State, 192 S.W.3d 248 (Ark. 2004) (accomplice liability and joint participation)
Purifoy v. State, 822 S.W.2d 374 (Ark. 1991) (accomplice liability and participation in crime)
Winters v. State, 427 S.W.3d 597 (Ark. 2013) (accomplice liability and criminal liability equality)
Smoak v. State, 385 S.W.3d 257 (Ark. 2011) (standard for directed verdict as sufficiency review)
Anderson v. State, 385 S.W.3d 214 (Ark. 2011) (sufficiency of evidence standard)
Ricks v. State, 873 S.W.2d 808 (Ark. 1994) (general sufficiency of evidence framework)
Victor v. Nebraska, 511 U.S. 1 (1994) (due process requirement to prove all elements beyond reasonable doubt)