Williams v. State, 2017 Ark. 287

Background

On Jan. 25, 2015, Laron Williams, Craig Wade, and James Gray Jr. were together after gambling and lacked money for gas; they made two trips to a Shell convenience store captured on time‑stamped surveillance video.
On the second trip, Wade shot and killed clerk Christopher Brown behind the counter; video shows Williams and Wade entering together, Wade firing, Williams stepping over the body, attempting to open the register, and searching the victim’s pockets; bloody footprints led from the counter to the getaway car.
Williams was charged separately with aggravated robbery and capital murder (life without parole for capital murder; concurrent sentences for robbery).
Williams moved for directed verdicts arguing insufficient evidence to establish accomplice liability and thus insufficient proof of capital murder; he also objected to admission of several gruesome crime‑scene photographs as cumulative and unduly prejudicial.
The trial court denied directed‑verdict motions and admitted four photographs; Williams was convicted on both counts and appealed.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Williams)	Held
1. Sufficiency of the evidence to prove accomplice liability and support capital‑murder conviction	Video, admissions, and circumstantial evidence show Williams planned the theft, acted in concert, aided the robbery, and thus is criminally liable for the killing committed in the course of the felony	Williams argued he only intended to steal beer, did not know Wade had a gun, was shocked by the shooting, and merely pretended to participate out of fear	Court held substantial evidence (video, conduct, association, flight) supported accomplice liability; intent for underlying felony suffices for felony‑murder; denied directed verdicts
2. Admissibility of gruesome crime‑scene photographs	Photos showed victim position, gunshot wound, bloody footprint proximity, and where Williams stepped; they aided witness description and revealed details not visible on video	Photos were cumulative to surveillance video and unduly prejudicial/inflammatory	Court held photographs served valid purposes, provided perspectives not clear on video, and probative value outweighed prejudice; no abuse of discretion
3. Plain‑error/complete‑record review under Ark. Sup. Ct. R. 4‑3(i)	N/A (appellate procedural requirement)	N/A	Court reviewed record for adverse rulings and found no prejudicial error; affirmed convictions

Key Cases Cited

Starling v. State, 2016 Ark. 20, 480 S.W.3d 158 (sufficiency standard on directed verdict)
Wells v. State, 2013 Ark. 389, 430 S.W.3d 65 (viewing evidence in light most favorable to the State)
Ross v. State, 346 Ark. 225, 57 S.W.3d 152 (definition of substantial evidence)
Purifoy v. State, 307 Ark. 482, 822 S.W.2d 374 (accomplice liability and concert of action may be shown circumstantially)
Jefferson v. State, 359 Ark. 454, 198 S.W.3d 527 (accomplice liability principles)
Grillot v. State, 353 Ark. 294, 107 S.W.3d 136 (participant liable for acts of accomplices)
Britt v. State, 334 Ark. 142, 974 S.W.2d 436 (intent for underlying felony sufficient for felony‑murder)
Jones v. State, 336 Ark. 191, 984 S.W.2d 432 (capital‑felony‑murder principles)
Anderson v. State, 2011 Ark. 461, 385 S.W.3d 214 (photograph admissibility reviewed for abuse of discretion)
Weger v. State, 315 Ark. 555, 869 S.W.2d 688 (photograph admissibility — probative vs. prejudicial)
Ramaker v. State, 345 Ark. 225, 46 S.W.3d 519 (inflammatory photos admissible if they aid understanding)
Harvey v. State, 292 Ark. 267, 729 S.W.2d 406 (photographs showing gore may be admissible for legitimate purposes)
Evans v. State, 2015 Ark. 240, 464 S.W.3d 916 (photos admissible to show body condition and position)
Airsman v. State, 2014 Ark. 500, 451 S.W.3d 565 (photos provide different perspective than video)
Smart v. State, 352 Ark. 522, 104 S.W.3d 386 (photographs admissible to assist jury and witnesses)
Smoak v. State, 2011 Ark. 529, 385 S.W.3d 257 (credibility determinations are for the jury)