The Arkansas Supreme Court on May 9, 2024, affirmed the convictions and sentences of Jacovan Bush for capital murder, aggravated residential burglary, aggravated robbery and theft, arising from the Feb. 15, 2018, killing of Devon Howard in Little Rock. Associate Justice Courtney Rae Hudson wrote the court’s opinion, which upheld a Pulaski County jury verdict and an aggregate sentence of life imprisonment without parole plus 40 years.

The court said the prosecution presented substantial evidence, including DNA from blood swabs that a forensic analyst testified matched Bush’s profile “within all scientific certainty,” and other witness and forensic testimony that a jury could reasonably credit. The court also rejected a challenge to the admission of lay‑opinion testimony from Officer Miranda Dollar, a Little Rock Police Department crime‑scene specialist, about observed physical changes in a bloodstain photographed at the scene.

The ruling matters because it clarifies two contested points in the appeal: the sufficiency of DNA evidence standing with other record evidence to support a capital‑murder conviction, and the admissibility under Arkansas Rule of Evidence 701 of a crime‑scene specialist’s lay opinion about whether a bloodstain appeared to have been fresher when first photographed. The trial court had denied Bush’s motion in limine to exclude Officer Dollar’s testimony and had twice denied motions for directed verdict.

At trial, witnesses Ericka Criswell and Tiana Howard testified about an armed entry into Howard’s apartment that night, including a scuffle in the bedroom, demands for money and a single gunshot they heard as people were leaving. Forensic testimony included Dr. Adam Craig’s autopsy findings that the victim died of a single gunshot that entered the back and exited the chest and was fired from within about three feet, and laboratory testimony that multiple swabs tested positive for blood and produced a DNA profile matching Bush.

Officer Dollar testified she photographed the same bloodstain twice and later concluded the stain “must have been fresher at that time” before appearing darker and more congealed in a later photograph; on cross‑examination she acknowledged inconsistencies about the reported time gap between photos and said she was not an expert in blood evidence but had attended courses on the topic. The court emphasized that the trial judge did not abuse her discretion in admitting the testimony because the opinion was rationally based on Dollar’s observations and experience as a crime‑scene specialist and because the jury is the arbiter of witness credibility.

Detective Rick Harmon testified that Bush became a suspect after a CODIS match from the laboratory results prompted an arrest warrant, and forensic DNA analyst Maddison Harrell testified about the DNA comparison and sample degradation factors. The appellate opinion reviewed precedent including Engram v. State and other Arkansas decisions holding DNA evidence can be sufficient to support a conviction, sometimes standing alone.

Bush had argued on appeal that the jury lacked sufficient evidence because witnesses did not identify him and because Officer Dollar’s later statement that a bloodstain had been fresher conflicted with earlier indications that the blood might have been dry when first photographed. The Supreme Court applied the standard of viewing the evidence in the light most favorable to the State and held the record contained substantial evidence to support the convictions.

The court also considered Arkansas Rules of Evidence 701 and 702 and related case law, concluding the trial court acted within its discretion in admitting Dollar’s lay opinion. The opinion noted the trial court’s findings that Dollar’s testimony was based on her experience at roughly 1,700 crime scenes over eight years and that her observation of photographic changes was presented for the jury to weigh.

The Supreme Court affirmed the Pulaski County Circuit Court judgment, concluding no prejudicial error requiring reversal had been shown. The case below was No. 60CR‑20‑708, tried before the Honorable Cathleen V. Compton. Attorneys of record on appeal included William O. “Bill” James and Drew Curtis for the appellant and A. Evangeline Bacon for the State; the Attorney General’s office filed the appellee brief.

The decision leaves intact the jury’s findings and the sentence imposed by the circuit court; no further action is noted in the opinion.