Ephriam v. State (Majority)
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In the Supreme Court of Arkansas, the defendant, Kevonce Ephriam, was appealing his conviction for capital murder. Ephriam was convicted for the death of his three-month-old son, whom he had custody of at the time of the incident. The child sustained numerous injuries, including bruises to his head, forehead, face, neck, and tongue; abrasions to his nose and neck; a torn frenulum; fractured ribs and vertebrae; and hemorrhaging in the soft tissue along his spinal column and on his neck, abdomen, and chest. Ephriam attempted to explain some of the injuries as accidents or results of his attempts to perform CPR, but his explanations were refuted by medical experts.
Ephriam argued that the State did not present sufficient evidence for capital murder and that his son's death could have been accidental. He also argued that the jury had to resort to speculation and conjecture to determine that he knowingly caused his son’s death under circumstances manifesting extreme indifference to the value of human life.
The court affirmed the conviction, finding that substantial evidence supported the capital-murder conviction. The court reasoned that the defendant admitted to threatening to harm the child and the mother, and his explanations for the child's injuries were refuted by medical experts, which led the jury to reasonably conclude that the injuries were not accidental but were inflicted by the defendant. The court also stated that there was no dispute that the child was under fourteen and that Ephriam was over eighteen at the time of the murder, fulfilling the age criteria for capital murder under Arkansas law.
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