Christopher Hooten v. State of Arkansas

2019 Ark. App. 519
CourtCourt of Appeals of Arkansas
DecidedNovember 6, 2019
StatusPublished
Cited by1 cases

This text of 2019 Ark. App. 519 (Christopher Hooten v. State of Arkansas) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Christopher Hooten v. State of Arkansas, 2019 Ark. App. 519 (Ark. Ct. App. 2019).

Opinion

Cite as 2019 Ark. App. 519 ARKANSAS COURT OF APPEALS Reason: I attest to the accuracy and integrity of this document Date: 2021-06-18 09:45:43 Foxit PhantomPDF Version: DIVISION I No. CR-19-410 9.7.5

Opinion Delivered: November 6, 2019 CHRISTOPHER HOOTEN APPEAL FROM THE CRAWFORD APPELLANT COUNTY CIRCUIT COURT [NO. 17CR-17-1253] V.

STATE OF ARKANSAS HONORABLE MICHAEL MEDLOCK, JUDGE APPELLEE AFFIRMED

PHILLIP T. WHITEAKER, Judge

Christopher Hooten was convicted by a Crawford County jury of aggravated assault,

first-degree criminal mischief, resisting arrest, and fleeing (both on foot and by vehicle) and

was sentenced as a habitual offender.1 Hooten appeals only his criminal-mischief and

resisting-arrest convictions, claiming that the trial court erred in denying his motions for a

directed verdict on those charges. We affirm.

On appeal, a motion for directed verdict is treated as a challenge to the sufficiency

of the evidence. Robinson v. State, 2017 Ark. App. 689, 537 S.W.3d 765. When the

sufficiency of the evidence is challenged, we view the evidence in the light most favorable

to the verdict and consider only the evidence supporting it under our standard of

1 Hooten was also charged with tampering with physical evidence; possession of drug paraphernalia; DWI; and possession of benzodiazepines. The State dropped the possession charges; he was acquitted of the tampering-with-physical-evidence charge; and the trial court directed a verdict on the DWI charge. review. Groomes v. State, 2019 Ark. App. 408, 586 S.W.3d 196. We will affirm if the finding

of guilt is supported by substantial evidence. Id. Substantial evidence is evidence of such

sufficient force and character that it will, with reasonable certainty, compel a conclusion one

way or the other, without resorting to speculation or conjecture. Id. With this standard in

mind, we turn to review the evidence presented to the jury.

On November 22, 2017, Hooten was involved in a high-speed chase on Interstate

40. State Trooper Ben Ibarra initially clocked Hooten’s vehicle traveling 87 miles per hour.

Trooper Ibarra activated his blue lights and attempted a traffic stop. Hooten refused to pull

over, and a chase ensued. During the chase, Hooten’s speed fluctuated between 80 and 130

miles per hour. Trooper John Bass joined the pursuit. Because Hooten refused to stop,

troopers then deployed spike strips along the interstate to deflate the tires on Hooten’s

vehicle. After hitting the spike strips, Hooten continued to travel over 90 miles per hour

on the vehicle’s rims. When the deployment of spike strips did not work, Trooper Bass

attempted to drive in front of Hooten to box him in, hoping to force him to slow down

and come to a stop. Instead of slowing down or stopping, Hooten attempted to pass Trooper

Bass. When he was unable to do so, he rammed Trooper Bass’s car multiple times.

Eventually, the troopers decided to perform a PIT2 maneuver to end the pursuit. Trooper

Bass executed the maneuver, which caused Hooten’s vehicle to stop in the median ditch.

2 PIT stands for “Precision Immobilization Technique.” A trooper executes a PIT maneuver by nudging the speeding vehicle’s rear end with the front quarter panel of the patrol car, forcing the vehicle to turn at a 90-degree angle. This causes the transmission to lock up so that the driver cannot put the vehicle back into drive. At that point, the vehicle is immobilized.

2 With his vehicle immobilized, Hooten exited the vehicle and fled on foot across the

eastbound traffic. Trooper Ibarra followed with his gun drawn. When Hooten reached a

tree line across the interstate, he encountered a fence. He stopped and turned to face

Trooper Ibarra. Trooper Ibarra holstered his weapon and attempted to restrain him. Hooten

refused to comply, and a struggle ensued. During the scuffle, Trooper Ibarra and Hooten

fell to the ground. The scuffle continued on the ground, making it difficult for Trooper

Ibarra to place Hooten in handcuffs. At some point during the struggle with Hooten,

Trooper Ibarra’s microphone clip broke off his belt. Hooten was eventually subdued and

placed under arrest.

Later, Trooper Bass had the damage to the passenger door of his vehicle repaired

with the costs exceeding $2,000. Based on this evidence, the jury convicted Hooten of

aggravated assault, first-degree criminal mischief, resisting arrest, and fleeing (both on foot

and by vehicle).

On appeal, Hooten challenges only his convictions for criminal mischief and resisting

arrest, contending that the State failed to present sufficient evidence to support either

conviction.3 A person commits criminal mischief in the first degree if he or she “purposely

and without legal justification destroys or causes damage to any property of another.” Ark.

Code Ann. § 5-38-203(a)(1) (Repl. 2013). This offense is a Class D felony if the amount of

3 At the close of the State’s case and at the close of all the evidence, Hooten moved for a directed verdict on the charges of criminal mischief and resisting arrest. He did not make directed-verdict motions on the charges of aggravated assault, fleeing on foot, or fleeing in a vehicle. Accordingly, the sufficiency of the evidence as to these charges is not an issue on appeal.

3 actual damage is more than $1,000 but less than $5,000. Ark. Code Ann. § 5-38-203(b)(2).

A person commits the offense of resisting arrest if he knowingly resists a person known by

him to be a law enforcement officer effecting an arrest. Ark. Code Ann. § 5-54-103(a)(1)

(Repl. 2016).

As to his criminal-mischief conviction, Hooten argues that the State failed to

sufficiently prove the amount of damages to the vehicle or that he acted purposely in causing

the damage. More specifically, he claims that Trooper Bass did not testify to the actual dollar

amount of the cost for repairs made to the damaged vehicle, and because no other evidence

of the cost of repairs was introduced, there was insufficient evidence to support the

conviction of criminal mischief. Admittedly, Trooper Bass did not testify to an actual dollar

amount of the repair costs. He did, however, testify that he took the car to be repaired and

that it cost over $2,000 to repair the vehicle. Trooper Bass’s testimony alone as to the cost

of repairs was sufficient to support the verdict. See White v. State, 2012 Ark. App. 302;

Andrews v. State, 2012 Ark. App. 597, 424 S.W.3d 349. Therefore, his argument fails in

this respect.

He also argues that the State failed to present sufficient evidence that he purposely

caused damage to the patrol car driven by Trooper Bass. He claims he was not purposely

trying to cause damage to the vehicle; he was simply attempting to flee the traffic stop. We

are not persuaded.

Clearly, Hooten engaged in a high-speed chase with speeds in excess of 90 miles an

hour. When officers attempted to slow him down, he rammed his vehicle into Trooper

Bass’s car, not once, but three separate times. By statutory provision, a person acts purposely

4 with respect to his or her conduct or a result of his or her conduct when it is the person’s

conscious object to engage in conduct of that nature or to cause the result. Ark. Code Ann.

§ 5-2-202(1) (Repl. 2013). Further, we have held that it is axiomatic that one is presumed

to intend the natural and probable consequences of his or her actions and that a criminal

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