Mark Edward Chumley v. State of Arkansas

2019 Ark. 383
CourtSupreme Court of Arkansas
DecidedDecember 12, 2019
StatusPublished

This text of 2019 Ark. 383 (Mark Edward Chumley v. State of Arkansas) is published on Counsel Stack Legal Research, covering Supreme Court of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mark Edward Chumley v. State of Arkansas, 2019 Ark. 383 (Ark. 2019).

Opinion

Digitally signed by Susan P. Williams Reason: I attest to the accuracy Cite as 2019 Ark. 383 and integrity of this document SUPREME COURT OF ARKANSAS Date: No. CR-19-420 2021.07.16 14:55:40 -05'00' Opinion Delivered: December 12, 2019

MARK EDWARD CHUMLEY APPELLANT APPEAL FROM THE WASHINGTON COUNTY CIRCUIT COURT V. [NO. 72CR-15-2035]

STATE OF ARKANSAS HONORABLE JOANNA TAYLOR, APPELLEE JUDGE AFFIRMED.

RHONDA K. WOOD, Associate Justice

A jury convicted Mark Chumley of capital murder and sentenced him to life

imprisonment. Chumley’s single argument on appeal is that the circuit court should have

granted his directed-verdict motion because there was insufficient evidence that he was

guilty of either capital or first-degree murder as felony murder during a rape or an attempted

rape or intentional murder. We affirm.

I. Background Chumley lived in Fayetteville with his girlfriend, Rebecca Lloyd, and her three

children. John (Chris) and Tori Davis also resided with them. Allegations of sexual abuse

and environmental neglect had been lodged against Rebecca. Investigators inquired into the

allegations, which upset Chumley, who believed someone was trying to set him up for the

sexual abuse of Rebecca’s daughter. Chumley blamed Tori for the investigation.

Chumley told Chris that Tori was cheating on him. Both men began hitting her

with baseball bats. Later, Chumley called Christopher and Desire Treat to come over to the house. Christopher and Desire had a history of animosity toward Tori. When Christopher

and Desire arrived, Chumley encouraged them also to strike Tori with baseball bats. While

the four took turns beating Tori, Chumley repeatedly asked her about calling the Arkansas

Department of Human Services (DHS). Chumley also questioned Tori about what she

knew of his own daughter’s rape. When Tori hesitated, Chumley would strike her across

the knees with a bat. Anytime Chris or Christopher hesitated in striking Tori, Chumley

would remind them of the things she had done to them.

At some point, Tori fell off the porch. She was then dragged into the driveway,

causing her pants to come off. Chumley instructed the others to retrieve a battery charger,

and he attached the jumper cable clips to Tori’s nipples. He then shocked her for several

minutes. Chumley also told the others to shove a baseball bat inside her vagina. When Desire

told Chumley that it “wasn’t going to work,” Chumley told Chris to retrieve some chainsaw

oil from the house to use as a lubricant. He told Desire to pour the oil inside her and try to

insert the bat again. Desire and Chumley again tried to insert the bat into Tori’s vagina

while the others held her down and kept her legs open.

The group then carried Tori to another house on the property. Once inside,

Chumley injected Tori with a white substance he took from a Mountain Dew bottle before

leaving. Tori died from her injuries. Chumley then directed Chris and Christopher to burn

the evidence. The following day, Chumley called 911. During the call, Chris got on the

phone and told the operator that he had killed Tori because she was threatening to divorce

him. Police who arrived on the scene thought Chumley was acting erratically and trying to

prevent them from talking to his accomplices separately.

2 The State pursued charges against Chumley, Chris, Christopher, and Desire.

Chumley’s accomplices all pleaded guilty and received term-of-years sentences and testified

at Chumley’s trial. The court instructed the jury under two types of capital murder and first-

degree murder—felony murder with the underlying felony of rape or attempted rape and

intentional murder. The jury convicted Chumley of capital murder and sentenced him to

life imprisonment without parole.

II. Sufficiency of the Evidence Chumley argues that the circuit court should have granted his directed-verdict

motion on the capital- and first-degree murder charges. He asserts that the State presented

insufficient evidence that he committed felony murder during a rape or an attempted rape

or intentional murder.

We evaluate the denial of a directed-verdict motion as a challenge to the sufficiency

of the evidence. Taylor v. State, 2010 Ark. 372, at 11, 372 S.W.3d 769, 776. In reviewing a

challenge to the sufficiency of the evidence, we determine whether the verdict is supported

by substantial evidence, direct or circumstantial. Id. Substantial evidence is evidence forceful

enough to compel a conclusion one way or the other beyond suspicion or conjecture. Id.

We view the evidence in the light most favorable to the verdict, and only evidence

supporting the verdict will be considered. Id.

When accomplice testimony is considered in reaching a verdict, Arkansas law

provides that a person cannot be convicted based upon the testimony of an accomplice

“unless corroborated by other evidence tending to connect the defendant . . . with the

commission of the offense.” Ark. Code Ann. § 16-89-111(e)(1)(A) (Supp. 2017).

3 Additionally, “corroboration is not sufficient if it merely shows that the offense was

committed and the circumstances thereof.” Ark. Code Ann. § 16-89-111(e)(1)(B).

Chumley argues that there was insufficient evidence for a capital-murder conviction

because he or his accomplices did not kill Tori in the course and furtherance of an attempted

rape and that he did not commit premeditated and deliberated murder. The State submitted

both theories to the jury. Because the State submitted the capital-murder charge to the jury

as a general verdict, the jury did not specify whether its findings were based on felony

murder, premeditated and deliberated capital murder, or both. We may affirm a general

verdict of capital murder if there was sufficient evidence to convict on either ground. See

Taylor, 2010 Ark. 372, at 15, 372 S.W.3d at 778.

Sufficient evidence supports the jury’s verdict on premeditated and deliberated

murder. A person commits capital murder if “with the premeditated and deliberated purpose

of causing death of another person, the person causes the death of any person.” Ark. Code

Ann. § 5-10-101(a)(4) (Supp. 2017). Premeditated and deliberated purpose occurs when it

is a person’s conscious object to cause death, having formed an intention to do so before

acting and as a result of weighing the consequences of this course of conduct. Fletcher v.

State, 2018 Ark. 261, 555 S.W.3d 858. Premeditation does not have to exist for any

particular length of time and may be formed in an instant. Id. Premeditation can be inferred

from circumstantial evidence including the type and character of the weapon used; the

nature, extent, and location of the wounds inflicted; and the conduct of the accused. Id.

Although some of the evidence proving premeditation and deliberation was provided

by Chumley’s accomplices, that testimony was corroborated by Chumley’s statement to

4 police, forensic evidence, and testimony from other witnesses. Chumley primarily argues

that the evidence did not show he intended to kill Tori. Rather, the evidence indicated that

he intended only to severely beat her. We disagree. A jury may infer premeditation and

deliberation from the number and nature of injuries to the victim and the time needed to

inflict them. See Brooks v. State, 2016 Ark. 305, at 7–8, 498 S.W.3d 292, 297 (finding that

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Related

Carmichael v. State
12 S.W.3d 225 (Supreme Court of Arkansas, 2000)
Chase v. State
973 S.W.2d 791 (Supreme Court of Arkansas, 1998)
Brooks v. State
2016 Ark. 305 (Supreme Court of Arkansas, 2016)
Taylor v. State
2010 Ark. 372 (Supreme Court of Arkansas, 2010)
Fletcher v. State
555 S.W.3d 858 (Supreme Court of Arkansas, 2018)

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