Phelps v. State

The defendant beat the victim to death with a rock and dragged his body into the woods where it was discovered a few weeks later.

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William Herbert Phelps was convicted of malice murder and concealing a death in connection with the beating death of Jeffrey Valdez.1 Phelps appeals, contending that the evidence was insufficient. Because the record demonstrates that the evidence was sufficient, we affirm. The evidence at trial showed that Phelps and the victim went to a club on July 17, 1999. They returned to Phelps’s sister’s apartment, where they slept. The next day, Phelps told his sister that some money was missing from his pockets and he suspected that the victim had taken it. Phelps’s sister told Phelps he couldn’t fight the victim in her apartment. Phelps’s sister agreed to drive Phelps and the victim to another location so Phelps could confront the victim. The victim agreed to go for a ride, not knowing the purpose. The three drove around awhile, parked by a hunting preserve, and walked down a dirt path about a mile. Phelps took a rock and began beating the victim in the head, and continued to throw the rock at the victim’s head while the victim lay on the ground. Phelps searched the victim for the missing money and then dragged the body into the woods. Phelps’s sister testified that when they left the victim, he was still alive. Phelps and his sister returned to her apartment, drove the victim’s truck to a parking lot, and threw away his keys, wallet and pager. The victim’s extensively decomposed body was found a few weeks later.

1. Phelps argues on appeal that the evidence was insufficient to conclude that the beating was the sole proximate cause of the victim’s death. The medical examiner, however, testified that the cause of death was blunt force injuries to the head. After reviewing the evidence in the light most favorable to the jury’s determination of guilt, we conclude that any rational trier of fact could have found Phelps guilty beyond a reasonable doubt of malice murder and that the evidence was sufficient to exclude any other reasonable hypothesis.2

Phelps v. State

The defendant beat the victim to death with a rock and dragged his body into the woods where it was discovered a few weeks later.

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