## Facts

- George Chapline, a member of the Arkansas House of Representatives, and M.D.L. Cook were indicted for conspiracy to commit bribery in connection with House Bill No. 135.
- The indictment alleged that Chapline and Cook agreed to pay about $1,400 to members of the Arkansas General Assembly to influence their votes in favor of the bill.
- After the bill initially failed in the House, Chapline met with A.F. Mayberry and other supporters of the bill.
- At that meeting, Chapline stated that it would take about $1,000 to secure the bill’s passage and suggested employing a lobbyist to “see certain members of the House.”
- When Mayberry asked whether the proposed fund was a “corruption fund,” Chapline responded that it was for “expenses.”
- The supporters selected Mayberry to handle the money and to hire someone to help get the bill passed.
- Chapline introduced Mayberry to Cook as someone who could “be of service” in securing passage of the bill.
- Cook told Mayberry that “nearly all of these important bills are passed with the use of money” and estimated that it would take at least $1,500 to ensure passage.
- Mayberry raised $1,475 from the bill’s supporters, and the money was placed in escrow to be paid to Cook if the bill became law.
- The bill later passed the legislature but was vetoed by the Governor, and the escrowed money was returned to the contributors.
- A jury convicted Chapline of conspiracy to commit bribery and assessed a $25 fine; the circuit court entered judgment on the verdict.
- Chapline appealed to the Arkansas Supreme Court, arguing that the evidence was insufficient to support the conviction.

## Issues

1. Whether the evidence was sufficient to permit the jury to find that Chapline joined an agreement to bribe legislators to secure passage of House Bill No. 135.
2. Whether a conspiracy had to be shown by direct proof of an express agreement, or could be inferred from surrounding circumstances and coordinated conduct.

## Decision

- The Arkansas Supreme Court affirmed Chapline’s conviction and the $25 fine.
- The court held that the jury could infer a corrupt agreement from the defendants’ statements and conduct, including Chapline’s comments about needing money to secure passage, his introduction of Mayberry to Cook, Cook’s statements about using money to pass bills, and the raising and escrowing of funds conditioned on the bill becoming law.
- The court rejected the argument that the plan’s failure to result in payments to legislators (and the return of the money after the Governor’s veto) defeated the conspiracy charge; the offense could be complete even though the ultimate objective was not achieved.

## Legal Principles

- A criminal conspiracy may be proved by circumstantial evidence; direct proof of an express agreement is not required.
- A conspiracy may be inferred when two or more persons pursue the same unlawful objective, each performing a part that, taken together, shows connected and cooperative action.
- The existence of a conspiracy does not depend on the success of the unlawful plan; the agreement and acts taken in furtherance of the unlawful purpose may be enough even if the intended bribery is not carried out.
- On review for sufficiency, the appellate court will sustain the verdict when the evidence and reasonable inferences from it permit a finding of guilt beyond a reasonable doubt.

## Conclusion

Chapline v. State affirmed a conviction for conspiracy to commit bribery based on evidence that Chapline and others organized and funded a plan to use money to influence legislative votes on House Bill No. 135, holding that the agreement could be inferred from coordinated acts and statements and was not negated by the Governor’s veto or the return of the escrowed funds.


Chapline v. State, 95 S.W. 477 (1906)