In Allen v. State, 296 Ark. 33, 39-40, 751 S.W.2d 347, 350 (1988), the murder victim received several blows to the head, cracking his skull. The State presented evidence that Allen had burglarized the victim's home, had beaten him, and had stolen his money, watch, credit cards, guns, and vehicle.
Allen confessed that he had entered the home in order to get keys and steal the car. He said that he did not intend to kill, but he confessed that he took a piece of angle iron with him in case the victim caught him or tried to shoot him. The supreme court held that the evidence supported theft as the underlying offense and object of the burglary, and that the murder resulted "in facilitating" the theft.