JONES v. STATE OF ARKANSAS (Majority)
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In this criminal case before the Supreme Court of Arkansas, the appellant, Fredrick Jones, was convicted by the Pulaski County Circuit Court of first-degree murder, first-degree battery, simultaneous possession of drugs and firearms, possession of cocaine with the purpose to deliver, possession of drug paraphernalia, fleeing, and being a felon in possession of a firearm. Jones was sentenced as a habitual offender to life in prison for the first-degree murder, sixty years in prison for first-degree battery, and an aggregate term of forty years on the remaining convictions, all to be served concurrently.
The case resulted from an incident on April 25, 2020, where Jones shot a man and subsequently fled from the police the next day when the victim's daughter identified him. During the high-speed chase, Jones ran a red light, striking a van occupied by Jose and Virginia Hernandez. Jose Hernandez died from his injuries and Virginia Hernandez suffered serious physical injuries. The police discovered firearms and cocaine in Jones's vehicle after the crash.
Jones appealed his convictions for first-degree murder and first-degree battery, arguing that the state had failed to prove that these crimes were committed "in furtherance of" his fleeing from police. He contended that while he drove his vehicle at a high speed and ran a red light to evade the police, the collision with the victims' vehicle and the resulting injuries did not promote his flight.
The Supreme Court of Arkansas affirmed the lower court's convictions. The court held that there was substantial evidence proving that Jones, with the intent to evade the police (the underlying felony), caused the death of Jose Hernandez and seriously injured Virginia Hernandez in the process of fleeing. The court explained that for a conviction of felony murder, the defendant's primary goal must be the commission of the underlying felony, not the murder or battery itself. The court found that Jones's primary intent was to flee from the police, and in the course of and in furtherance of that flight, he caused the death and serious physical injuries. Therefore, the court ruled that the circuit court properly denied Jones's motions to dismiss.
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