Willie Lee Martin v. State of Mississippi
| Docket Number: | 2002-KA-01160-COA | |
| Oral Argument: | 01-21-2004 | |
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| Additional Case Information: |
Topic: Capital murder - Weight of evidence - Right to speedy trial - Prior conviction of co-defendant - In-court identification - Preservation of evidence - Corpus delicti - Right to confront witnesses - Jury notes - UCCCR 3.14 |
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| Party Name: | Attorney Name: | |||
| Appellant: | Willie Lee Martin |
Jeffery P. Reynolds; Daniel M. Weir; Benjamin Z. Wise |
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| Appellee: | State of Mississippi | Charles W. Maris, Jr.; Deirdre McCrory |
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| Topic: | Capital murder - Weight of evidence - Right to speedy trial - Prior conviction of co-defendant - In-court identification - Preservation of evidence - Corpus delicti - Right to confront witnesses - Jury notes - UCCCR 3.14 |
| Summary of the Facts: | Willie Martin was found guilty of capital murder and was sentenced to life imprisonment without the possibility of parole. He appeals. |
| Summary of Opinion Analysis: | Issue 1: Weight of evidence Martin argues that the verdict was contrary to the overwhelming weight of the evidence, because the State's case relied heavily on hearsay testimony and questionable opinion evidence. The State presented testimony from a person which described the events and identified the persons involved in this matter. Although Martin argues that the testimony about his role in the matter is not accurate, any factual disputes are to be properly resolved by the jury. Issue 2: Right to speedy trial Martin argues that his right to a speedy trial was violated. In determining whether the right to a speedy trial has been denied, the court should consider length of the delay, reason for the delay, whether the defendant has asserted his right, and any resulting prejudice. Although the record shows that several continuances were granted, it does not indicate which party requested the continuances or why they were granted. Martin claims prejudice from the death of an alibi witness. However, he did not specifically state to what the alibi witness would have testified. Without greater specificity, Martin has failed to show actual prejudice which resulted from the delay. Issue 3: Prior conviction Martin argues that his attorneys were not allowed to delve into the co-defendant's prior armed robbery conviction during pretrial motions. The prior convictions were armed robbery and drug convictions. There was no abuse of the court’s discretion in accepting the State's argument that the prior convictions were not probative of the truth and veracity of the witness's testimony. Issue 4: In-court identification Martin argues that the court erred in permitting an in-court identification, because the photo line-up was impermissibly suggestive the suspect in only one photograph had a ponytail. If there is credible evidence supporting the trial court's findings that, considering the totality of the circumstances, in-court identification testimony was not impermissibly tainted, the findings will not be disturbed. Here, there was no abuse of discretion by the court. Issue 5: Preservation of evidence Martin argues that the State failed to preserve the skull or a tissue sample for subsequent DNA analysis comparison to the torso. Unless Martin can show bad faith on the part of the police, failure to preserve potentially useful evidence does not constitute a denial of due process of law. Here, the record does not show proof of bad faith. Issue 6: Corpus delicti Martin argues that the State failed to prove each element of corpus delicti beyond a reasonable doubt. The corpus delicti which the State must show in a homicide case consists of the death of a human being, and a criminal agency causing the death. Here, the State offered the co-defendant’s testimony that she saw Martin and Jones kicking and beating the victim, testimony from the victim's mother and sister who identified the victim's tattoo from photographs of the recovered torso, and testimony from an expert who testified that the manner of death was homicide. Based on the evidence presented, the court did not err in denying Martin's instruction that the corpus delicti had not been proven beyond a reasonable doubt. Issue 7: Right to confront witnesses Martin argues that the forensic pathologist improperly consulted with and relied upon the opinions of a forensic anthropologist and that reliance prevented him from confronting and cross-examining the anthropologist. However, the pathologist testified that he reached his conclusions independently. Therefore, there is no violation of Martin's fundamental right to confront witnesses. Issue 8: Jury notes Martin argues that allowing the jurors to take notes and use their notes during deliberations was prejudicial to his case. Because UCCCR 3.14, adopted effective April 18, 2002, grants the court the discretion to allow note-taking by jurors and their use in deliberation, any error is harmless. |
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