Eason v. State

A jury found Michael Eason guilty of aggravated assault. He appeals, challenging the sufficiency of the evidence and the trial court’s failure to direct a verdict of acquittal. He also argues that he received ineffective assistance of trial counsel. For reasons that follow, we find the evidence sufficient to sustain Eason’s conviction, but remand for a hearing on his ineffective assistance claim. 1. In addressing Eason’s arguments regarding the sufficiency of the evidence and the denial of his motion for directed verdict, we apply the same standard of review.1 “We view the evidence in the light most favorable to the jury’s verdict and determine whether any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.”2 On appeal, Eason no longer enjoys the presumption of innocence; moreover, an appellate court does not weigh the evidence or determine witness credibility but only determines whether the evidence is sufficient. . . . Conflicts in the testimony of the witnesses, including the State’s witnesses, are a matter of credibility for the jury to resolve. As long as there is some competent evidence, even though contradicted, to support each fact necessary to make out the State’s case, the jury’s verdict will be upheld.3 Viewed in this manner, the evidence shows that, on the night of December 30, 2000, Eason walked to the home of his neighbor, Bruce Smith, looking for a replacement part for a broken heater. Smith did not have the proper part, but Eason stayed to drink beer and watch television with Smith and Smith’s girlfriend. When Smith’s girlfriend and Eason began to argue, Smith drove him home.

On the way, Smith grew concerned that Eason’s house did not have heat, and he invited Eason, Eason’s live-in girlfriend, Christy Caul, and Caul’s eight-month-old baby to spend the night at his house. When he and Eason arrived at Eason’s residence, Smith noticed that the house was dark, and he concluded that the electricity was also out. Smith told Eason to get Caul and the baby so that they could return to Smith’s home.