McCullum v. State

Summary

The court affirmed McCullum’s convictions for malice murder and two rapes, concluding that the evidence was constitutionally sufficient and that the trial court properly denied his motions to dismiss on speedy-trial grounds and to sever the rape charge involving C.C. The court held that constitutional sufficiency review measures the evidence against the statutory elements of the charged offense, not additional factual details alleged in the indictment, and that the evidence supported findings that McCullum’s beating and rape of Blackwell proximately caused her death. It also held that the decade-plus delay did not violate the constitutional speedy-trial right and that joinder was within the trial court’s discretion because evidence of C.C.’s rape would have been admissible in a separate trial and McCullum showed no jury confusion or prejudice.