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Reed v. State
Citations: 326 Ark. 27; 929 S.W.2d 703; 1996 Ark. LEXIS 475Docket: CR 96-310
Court: Supreme Court of Arkansas; September 23, 1996; Arkansas; State Supreme Court
James Edward Reed was convicted of two counts of burglary, two counts of theft, and one count of arson, which occurred when he and two accomplices, Eric Thul and Scotty Lewis, skipped school and decided to burglarize homes. Reed was tried alongside Thul, and his appeal focused on the Trial Court’s refusal to give a non-AMCI jury instruction on accomplice responsibility. The proffered instruction, which Thul's counsel argued was supported by the precedent in Fight v. State, emphasized that an accomplice is only responsible for acts they had a shared criminal intent in committing. During the trial, evidence indicated Reed's involvement in the burglary of the Tritch home and the subsequent arson, with Thul testifying that Reed set fire to items in the house. Reed claimed he only acted as a lookout, corroborated by Lewis, who suggested that Thul had acted independently in setting the fire. The Trial Court opted for the AMCI 2d 401 instruction, clarifying that the State did not argue that Reed and Thul acted alone in committing the offenses. The court found the evidence sufficient to support the convictions without the need for the non-AMCI instruction. A person can be criminally liable for the actions of another if they are an accomplice in an offense, which involves soliciting, advising, encouraging, coercing, or aiding the other person in committing the crime. The term "purpose" refers to acting with the conscious objective to engage in specific conduct or to achieve a particular result. Under Arkansas law, arson occurs when a person intentionally starts a fire to damage an occupiable structure. Mr. Reed argued that the jury should have been instructed that the State needed to prove his "conscious object" to commit arson to convict him as an accomplice. This argument is akin to that raised in Misskelley v. State, where it was ruled that an accomplice instruction based on AMCI 401 was appropriate, as it correctly reflected the law without requiring proof of the accomplice's specific intent to commit the crime. The court affirmed that the jury could find Mr. Reed liable as an accomplice simply by showing that he assisted Mr. Thul with the intent to facilitate the arson, without needing to establish Mr. Reed’s conscious objective to commit the crime. The instruction provided by the Trial Court was deemed appropriate and the conviction was upheld.