Williams v. State, 2015 Ark. 316

On April 5, 2013, Tangela Walton disappeared after a phone/bus trip between Warren and Monticello; she was later found dead and the manner of death was homicide by asphyxia of undetermined means.
Fred L. Williams (on-again/off-again boyfriend) was interviewed multiple times; his accounts evolved and he ultimately admitted having sex with Walton, using a bag over her head for oxygen-deprivation sexual activity, and later finding her smothered.
Williams told police he had a seizure during sex, awoke to find Walton unresponsive, stayed in the house for hours, then carried and buried her clothed body; he also admitted disposing of a necktie and bag and sent texts to Walton’s phone to create an alibi.
Autopsy showed multiple recent bruises (including throat) and concluded death by asphyxia with manner homicide; no evidence of binding.
Williams was charged with first-degree murder and abuse of a corpse; a jury convicted him on both counts and he was sentenced as a habitual offender to life imprisonment (plus concurrent 20 years on the corpse count). He appealed, arguing the evidence was insufficient and that the convictions rested on speculation.

Issue	Plaintiff's Argument (Williams)	Defendant's Argument (State)	Held
Sufficiency of evidence for 1st-degree murder (purpose to cause death)	Evidence only shows death occurred in his home; no proof he purposely caused death; conviction based on circumstantial evidence and speculation	Jury could credit Williams’s admission that he intentionally deprived Walton of oxygen and reject his accidental-seizure theory; consciousness-of-guilt acts and injuries support purposeful intent	Affirmed — substantial circumstantial evidence supported finding of purposeful intent to cause death
Sufficiency of evidence for abuse of a corpse	Burial of Walton clothed is not mutilation or offensive mistreatment; conduct not within statutory offense	Jury could deem burial in a shallow grave outside normal practices and therefore ‘‘offensive to a person of reasonable sensibilities’’ under the statute	Affirmed — jury reasonably found concealment/burial was outside normal practices and satisfied the statute

Gilliland v. State, 361 S.W.3d 279 (2010) (standard for reviewing sufficiency of the evidence)
Marcyniuk v. State, 373 S.W.3d 243 (2010) (circumstantial evidence must be consistent with guilt and exclude reasonable innocence)
Boldin v. State, 283 S.W.3d 565 (2008) (suspicion is insufficient when two equally reasonable conclusions exist)
Norris v. State, 368 S.W.3d 52 (2010) (jury decides whether circumstantial evidence excludes other reasonable hypotheses)
Wyles v. State, 249 S.W.3d 782 (2007) (presumption that one intends natural and probable consequences of actions)
Coggin v. State, 156 S.W.3d 712 (2004) (efforts to conceal a crime and lies can show consciousness of guilt)
Ross v. State, 57 S.W.3d 152 (2001) (credibility and resolution of inconsistent evidence are jury questions)
Watson v. State, 188 S.W.3d 921 (2004) (jury may rely on common sense and experience to determine reasonableness)