Wells v. State
2013 Ark. 389
| Ark. | 2013Background
- Wells was convicted of capital murder in the course of aggravated robbery and sentenced to life imprisonment for Patel's death at the Lynwood Motel in Hot Springs.
- Wells and Smith tried to cash a forged $2,700 check; the attempt failed at Gene’s Liquor Store in Malvern, where Wells was recognized by the night manager.
- After failing at the liquor store, Wells drove to Hot Springs with Smith, armed himself, entered Patel’s motel office, and shot Patel.
- Kuykendall and Hasley observed a man driving a Pontiac G-6 leaving the motel and pursuing the vehicle to obtain a license plate.
- Wells confessed to investigators that he killed Patel; his confession was read to the jury and admitted into evidence.
- Wells argued there was insufficient evidence that Patel’s murder occurred during the course of an aggravated robbery and challenged an accomplice-liability instruction for Smith.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for aggravated robbery | Wells contends Patel’s murder isn’t proven to occur in the course of aggravated robbery. | Wells asserts the State failed to prove the underlying felony of aggravated robbery beyond reasonable doubt. | Substantial evidence supports the robbery-murder nexus. |
| Requirement of an accomplice-testimony instruction | Wells claims Smith was an accomplice and instruction AMI Crim.2d 403 was warranted. | State contends no sufficient basis to treat Smith as an accomplice demanding instruction. | Harmless error, as corroborating evidence and Wells’s confession independently established the crime. |
Key Cases Cited
- Huff v. State, 2012 Ark. 388 (Ark. 2012) (substantial evidence standard for sufficiency review)
- Stevenson v. State, 2013 Ark. 100 (Ark. 2013) (circumstantial evidence sufficiency on appeal)
- Jones v. State, 386 Ark. 191 (Ark. 1999) (felony-murder elements and intent)
- Abdullah v. State, 301 Ark. 235 (Ark. 1990) (accomplice liability framework in mixed questions of law and fact)
- Henderson v. State, 255 Ark. 870 (Ark. 1974) (evidence-corroboration standards for accomplice testimony)
- Hickman v. State, 372 Ark. 438 (Ark. 2008) (harmless-error review procedures)
- Taylor v. State, 2010 Ark. 372 (Ark. 2010) (standard for submitting jury instructions)
- Meeks v. State, 317 Ark. 411 (Ark. 1994) (credibility and appellate review of verdicts)
- Jackson v. State, 193 Ark. 776 (Ark. 1937) (presence and knowledge as basis for accomplice instruction)
- Meadows v. State, 2012 Ark. 57 (Ark. 2012) (accomplice participation need not be in every facet of the crime)
- King v. State, 323 Ark. 671 (Ark. 1996) (failure to give accomplice instruction requires abuse of discretion ruling)