Steggall v. State, 99-712
Decision Date | 20 January 2000 |
Docket Number | 99-712 |
Citation | 8 S.W.3d 538 |
Parties | Steven A. STEGGALL v. STATE of Arkansas CR 99-712 ___ S.W.3d ___ Opinion delivered |
Court | Arkansas Supreme Court |
Appeal from Jackson Circuit Court; Harold S. Erwin, Judge; affirmed.
1. Evidence -- sufficiency of -- considered first on appeal. -- When an appellant challenges the sufficiency of the evidence, the appellate court addresses the issue before all others.
2. Motions -- directed verdict -- challenge to sufficiency of evidence. -- A directed-verdict motion is a challenge to the sufficiency of the evidence.
3. Evidence -- sufficiency of -- test for determining. -- The test for determining sufficiency of the evidence is whether there is substantial evidence to support the verdict; on appeal, when a defendant challenges the sufficiency of the evidence convicting him, the evidence is viewed in the light most favorable to the State; evidence is substantial if it is of sufficient force and character to compel reasonable minds to reach a conclusion and pass beyond suspicion and conjecture; only evidence supporting the verdict will be considered.
4. Evidence -- circumstantial evidence -- when sufficient. -- The appellate court makes no distinction between circumstantial and direct evidence when reviewing for sufficiency of the evidence; however, for circumstantial evidence to be sufficient, it must exclude every other reasonable hypothesis consistent with innocence; whether the evidence excludes every hypothesis is left to the jury to determine.
5. Evidence -- circumstantial evidence -- proof of guilt. -- Guilt may be proved in the absence of eyewitness testimony, and evidence of guilt is not less because it is circumstantial.
6. Criminal law -- intent or state of mind -- usually inferred from circumstances. -- A criminal defendant's intent or state of mind is rarely capable of proof by direct evidence and must usually be inferred from the circumstances of the crime.
7. Criminal law -- culpable mental states -- "knowingly" defined. -- Under Ark. Code Ann. § 5-2-202 (Repl. 1993), "[a] person acts knowingly with respect to a result of his conduct when he is aware that it is practically certain that his conduct will cause such a result."
8. Jury -- application of common sense -- inference of guilt from improbable explanations. -- A jury need not lay aside its common sense in evaluating the ordinary affairs of life, and it may infer a defendant's guilt from improbable explanations of incriminating conduct.
9. Evidence -- circumstantial evidence -- may constitute substantial evidence of guilt. -- Circumstantial evidence of a culpable mental state may constitute substantial evidence to sustain a guilty verdict.
10. Motions -- directed verdict -- denial proper where evidence was ample that appellant knowingly caused death of daughter. -- Where there was ample evidence, circumstantial and direct, for the jury to find that appellant knowingly caused the death of his infant daughter, denial of his directed-verdict motion was proper, and the court was correct in allowing the jury to consider the evidence.
11. Motions -- motion to suppress -- standard of review. -- When the appellate court reviews a trial court's ruling on a motion to suppress, it reviews the evidence in the light most favorable to the State and makes an independent determination based upon the totality of the circumstances; further, the appellate court will only reverse a trial court's ruling on a motion to suppress if the ruling was clearly erroneous.
12. Witnesses -- credibility -- province of factfinder. -- It is in the province of the finder of fact to determine the credibility of witnesses.
13. Criminal procedure -- confession -- State's burden. -- The burden is on the State to show that a defendant's confession was made after a voluntary, knowing, and intelligent waiver of his rights.
14. Criminal procedure -- confession -- test for waiver of rights. -- Where appellant's confession was given without counsel, the test was whether appellant was effectively warned of his rights and knowingly and willingly decided to waive them.
15. Criminal procedure -- assertion of right to counsel -- must be made with specificity. -- The assertion of the right to counsel and the right to remain silent must be made with specificity.
16. Criminal procedure -- waiver of rights -- totality-of-circumstances review.-- Only if the totality of the circumstances surrounding an interrogation reveals both an uncoerced choice and the requisite level of comprehension may a court properly conclude that Miranda rights have been waived; the "totality of the circumstances" review mandates an inquiry into an evaluation of age, experience, education, background, and intelligence, and into whether a defendant has the capacity to understand the warnings given him, the nature of his Fifth Amendment rights, and the consequences of waiving those rights; a court must look at the totality of the circumstances to see if the State proved that a defendant had the requisite level of comprehension to waive his Fifth and Sixth Amendment rights.
17. Motions -- motion to suppress -- trial court not clearly erroneous in denying. -- Where appellant was read his rights on three occasions and indicated on each occasion that he understood those rights; where there was no indication that he requested an attorney during the questioning; where, considering appellant's age, education, and experience, no special circumstances existed to invalidate his waiver; where appellant was an adult who had graduated from high school and had completed some college credits; where appellant showed nosigns of being under the influence of any drug or delusions; and where appellant had prior experience with law enforcement, the supreme court concluded that the trial court was not clearly erroneous in denying appellant's motion to suppress; affirmed.
Val P. Price and Scott Nance; and Terry Goodwin Jones, Law Student Admitted to Practice Pursuant to Rule XV(E)(1)(6) of Rules Governing Admission to the Bar of the Arkansas Supreme Court; for appellant.
Mark Pryor, Att'y Gen., by: Brad Newman, Ass't Att'y Gen., for appellee.
Appellant Steven A. Steggall appeals his capital-murder conviction for the death of his three-month-old daughter, Haylee Brianne Stice ("Haylee"), who died of traumatic injuries to her head and body. The trial court sentenced Steggall to life in prison. Hence, we have jurisdiction under Ark. Sup. Ct. R. 1-2(a)(2). On appeal, Steggall argues that the prosecution adduced insufficient facts to support a capital-murder conviction, and that his statements to the police should have been suppressed because he requested that an attorney be present during the statements. We find no error and affirm.
On April 2, 1998, Steggall and Misty Stice ("Stice"), Haylee's mother, admitted Haylee to the emergency room of a Newport hospital. Steggall initially told investigators he had called 911 after observing bleeding from the child's nose after he laid her down to sleep. Haylee was transported by helicopter shortly thereafter to Arkansas Children's Hospital in Little Rock, where she was first seen by Dr. Stephen Schexnayder, a pediatric critical-care and emergency-medicines physician. Dr. Schexnayder testified at trial that upon initial evaluation, he and his team found Haylee to be "a very severely ill child who was in shock." According to Dr. Schexnayder, she was "severely neurologically injured, meaning she was comatose."
Dr. Charles Albert James, a pediatric radiologist, conducted several diagnostic tests including a skeletal survey or full-body x-ray, a CT scan of Haylee's brain, and a bone scan to identify bone abnormalities. Dr. Schexnayder and Dr. James reviewed the test results. Both doctors noted that Haylee had suffered an"extensive skull fracture" on the right side of her head, resulting in hemorrhaging on the brain surface and damage to both frontal lobes of the brain. The x-rays and bone scan also revealed that Haylee suffered two occurrences of rib fractures -- one occurrence approximately two weeks before this hospital admission and the other related to the April 2 occurrence. The tests also revealed that Haylee had suffered a fractured forearm, which was healing, indicating that it was over a week old at the time of admission on April 2. Both doctors opined that the old and new injuries were consistent with child abuse. Specifically, they believed the injuries reflected "shaken baby syndrome" and "shake and slam syndrome." Children's Hospital reported the incident to the Jackson County Sheriff's Department as suspected child abuse.
Steggall made three statements to the police regarding the incident on April 2, 1998. The police first questioned Steggall on the evening of April 3, 1998, at Arkansas Children's Hospital. Chief Deputy David Lucas and Detective Charles Vaughn with the Jackson County Sheriff's Department conducted the interview, which was audio-taped. Prior to conducting the interview, Lucas had Steggall answer and initial a standard Miranda rights form. The statement was later transcribed. In this first statement, Steggall recounted the events of the night before. He stated that he laid Haylee down in her bed on her stomach and finished some housecleaning. He stated he heard a choking sound, went to check on Haylee, and noticed when he rolled Haylee over on her side that some blood came out of her nose. Steggall stated that when he picked her up she was limp, and he then called 911. Throughout this statement, Steggall denied ever shaking or dropping Haylee.
Steggall again met with the police investigators on the morning of April 8, 1998. State Police Investigator Charles Beall orally advised Steggall of his rights before taking the statement, and Steggall completed a standard Miranda waiver form provided by the police. Steggall indicated that he understood his rights and would waive them. Steggall dictated a statement...
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