Tiffany Harris v. State of Arkansas

2021 Ark. App. 215
CourtCourt of Appeals of Arkansas
DecidedMay 5, 2021
StatusPublished

This text of 2021 Ark. App. 215 (Tiffany Harris 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
Tiffany Harris v. State of Arkansas, 2021 Ark. App. 215 (Ark. Ct. App. 2021).

Opinion

Cite as 2021 Ark. App. 215 Elizabeth Perry ARKANSAS COURT OF APPEALS I attest to the accuracy and DIVISION I integrity of this document No. CR-20-570 2023.06.27 11:41:31 -05'00' 2023.001.20174 Opinion Delivered: May 5, 2021 TIFFANY HARRIS APPELLANT APPEAL FROM THE PULASKI V. COUNTY CIRCUIT COURT, FOURTH DIVISION STATE OF ARKANSAS [NO. 60CR-18-4797] APPELLEE HONORABLE HERBERT T. WRIGHT, JR., JUDGE

AFFIRMED

RITA W. GRUBER, Judge

A Pulaski County jury convicted appellant Tiffany Harris of third-degree domestic

battering, and after the parties waived jury sentencing, the circuit court sentenced her to

twelve months’ probation and ordered her to pay a $2500 fine and court costs. Appellant’s

sole point on appeal challenges the sufficiency of the evidence. We affirm.

Appellant was charged with first-degree domestic battering and terroristic act arising

out of an October 2018 incident involving her live-in boyfriend. A jury trial took place on

February 12–13, 2020. Officer Christopher Crowder of the Little Rock Police Department

testified that he responded to Baptist Health Medical Center on October 16, 2018, in

relation to a shooting incident. He found Elijah Muldrow in the emergency room with a

bloody gunshot wound to his leg. Based on his conversation with Muldrow, he was able to develop appellant as a suspect. Officer Crowder testified that he observed Muldrow’s Nissan

Altima at the hospital with a “bullet slug” in the passenger-side door.

Muldrow testified that appellant is his fiancée and they had been “serious” since

around 2014 or 2015. They have one child together. He described their relationship as

“good” and “peaceful” but said “we do have our days.” He indicated that although they

argued, the arguments had never involved physical violence. Muldrow said they had an

argument on October 16, 2018. He acknowledged his short temper and testified that he

punched a hole in the wall in their home that day. He said that the argument was “big

enough” that they were breaking up for the time being. He described himself as “enraged”

as he packed his belongings and placed them outside the front door. He walked back and

forth between the house and his car placing his belongings in a pile. Muldrow testified that

he did not know appellant had a gun until “the warning shots came” at which time he was

walking up the driveway toward the front door where she was standing. He stated that he

did not see the gun aimed at him, which is why he thought they were warning shots. He

thought one of the shots ricocheted and hit him in the leg because he did not see it hit him

and did not feel it at first. Once he realized he had been shot, he drove himself to the

emergency room where he was treated for a gunshot wound. Muldrow explained that the

bullet went in straight through his leg in his thigh area.

At the close of the State’s case, appellant moved for a directed verdict:

We move for a directed verdict. We don’t believe the State met its burden of proof. To prove Domestic Battery in the First Degree, the State would have to prove that there was purposeful conduct. For there to be purposeful conduct, the State would have to show that it was Ms. Harris’ conscious object to engage in conduct of that nature, that would have caused -- the cause of his injury. The testimony in the record at this time is the testimony from the victim himself, who said the gun was not

2 pointed at him and he was raging and upset, and that he did not believe that she was trying to shoot him. His testimony was, it was a ricochet, that the bullet hit the ground and then hit his leg. That is not purposeful conduct. So we move for a directed verdict on that basis.

After the court denied the motion, appellant’s counsel withdrew the request for “lessors.”

Appellant testified in her defense that she was not aiming at Muldrow and did not

intend to shoot him. She added that she would never have gotten the weapon if she had

not been scared. She indicated that she became scared after he started knocking things over

and punched a hole in the wall. Appellant said that Muldrow had never put his hands on

her during their relationship, and she never feared him but described him as having “a little

temper.” Appellant testified that after she got her gun, she was at the front door and

Muldrow was outside, said something threatening, and was being combative. After she told

him that he needed to leave, he started coming down the driveway toward her, and she

fired two warning shots, which seemed to “amplify” him. She then fired a third shot toward

the ground after which Muldrow let out a noise, walked to his car, and drove off. Appellant

did not know that Muldrow had been shot but learned of it from her mother.

On cross-examination, when asked where she fired, she replied, “I fired two warning

shots in the air, one clearly hit his vehicle. Our house is on an incline and so it’s up. Maybe

my aim was wrong. I don’t know. But I fired two warning shots telling him to leave.”

At the conclusion of her testimony, appellant’s counsel renewed the motion for

directed verdict, which was again denied. When the parties reviewed jury instructions prior

to the case being submitted to the jury, the State requested that the lesser-included offense

of third-degree domestic battering be included. Appellant’s counsel acknowledged that

third-degree domestic battering is a lesser-included offense of first-degree domestic battering

3 but argued that they “have a right to either go all or nothing or include the lessors.”

However, appellant’s counsel ultimately conceded that the “law says that the lessor can be

given if it is supported by the evidence” but argued that appellant had the right to waive it

like the right to waive a jury trial. Ultimately, the court gave the instruction.

Appellant was convicted of third-degree domestic battering and sentenced to twelve

months’ probation and ordered to pay a $2500 fine and court costs. On February 24, 2020,

appellant filed a motion for a new trial arguing that she did not receive a fair trial and the

evidence was insufficient to support the conviction of third-degree domestic battering. 1 The

sentencing order was filed March 2, 2020, and appellant filed a notice of appeal on March

31, 2020.

When the sufficiency of the evidence is challenged in a criminal conviction, our

court views the evidence in the light most favorable to the verdict and considers only the

evidence supporting it. Adkins v. State, 371 Ark. 159, 264 S.W.3d 523 (2007). 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. Fernandez

v. State, 2010 Ark. 148, 362 S.W.3d 905.

Arkansas Code Annotated section 5-26-305(a)(3) (Supp. 2019) provides in part that

a person commits domestic battering in the third degree if the person negligently causes

1 The circuit court never ruled on the posttrial motion; thus, it was deemed denied as of the thirtieth day. See Ark. R. Crim. P. 33.3 (c). Appellant did not file a notice of appeal from the denial of the motion for new trial and does not challenge it on appeal.

4 physical injury to a family or household member by means of a deadly weapon. Section 5-

2-202(4) (Repl.

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Related

Ramaker v. State
46 S.W.3d 519 (Supreme Court of Arkansas, 2001)
Adkins v. State
264 S.W.3d 523 (Supreme Court of Arkansas, 2007)
Fernandez v. State
2010 Ark. 148 (Supreme Court of Arkansas, 2010)

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2021 Ark. App. 215, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tiffany-harris-v-state-of-arkansas-arkctapp-2021.