Thornton v. State

Summary

The Arkansas Supreme Court reversed and dismissed Justin Jamaille Thornton’s capital-murder conviction, holding that the circumstantial evidence was insufficient to establish premeditation and deliberation beyond speculation and conjecture. The court also concluded that the circuit court improperly shifted the burden of proof to Thornton. Two justices dissented, concluding that substantial evidence supported the conviction.

Holdings

1. The evidence was insufficient to establish beyond a reasonable doubt that Thornton acted with a premeditated and deliberated purpose to cause Turner’s death.
2. The circuit court improperly shifted the burden of proof to Thornton by treating the absence of evidence supporting an alternative explanation as evidence that he acted deliberately.

Questions Presented

1. Whether substantial evidence established that Thornton acted with the premeditated and deliberated purpose required for capital murder.
2. Whether the circuit court improperly relied on speculation and conjecture and shifted the burden of proof when finding premeditation and deliberation.

Disposition

reversed_and_remanded