Anthony Dewayne Brown v. State of Arkansas

Summary

The court affirmed Brown's first-degree-murder conviction and life sentence, holding that substantial evidence supported a finding that his act of setting Burton on fire caused Burton's death. Burton's heart disease was a concurrent cause, but it was not clearly sufficient to cause death without the burns, and the burns were therefore a but-for cause. The court also declined to consider Brown's unsupported argument that the two-hour interval between the burning and death defeated causation.