Little v. State
In Little v. State, 261 Ark. 859, 554 S.W.2d 312 (1977), the supreme court ruled that the trial court, giving an instruction on circumstantial evidence, had not misled the jury by using the word "should" instead of "must" in stating that circumstances should point to and be consistent with guilt but should be inconsistent with any other reasonable hypothesis.
The Little court opined that use of the word "must" would have been preferable to the use of "should," but the court noted that the words are often synonymous. 261 Ark. at 884, 554 S.W.2d at 324.