Craft v. State
| Docket Number: | 2005-KA-02187-COA Linked Case(s): 2005-KA-02187-COA2005-CT-02187-SCT |
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| Oral Argument: | 03-28-2007 | |
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| Court of Appeals: |
Opinion Link Opinion Date: 07-24-2007 Opinion Author: GRIFFIS, J. Holding: Affirmed |
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| Additional Case Information: |
Topic: Murder - Deliberate design instruction - Sufficiency of evidence - Mistrial Judge(s) Concurring: KING, C.J., LEE AND MYERS, P.JJ., IRVING, CHANDLER, BARNES, ISHEE, ROBERTS AND CARLTON, JJ. Procedural History: Jury Trial Nature of the Case: CRIMINAL - FELONY |
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| Trial Court: |
Date of Trial Judgment: 10-12-2005 Appealed from: Hinds County Circuit Court Judge: Bobby DeLaughter Disposition: CONVICTION OF MURDER AND SENTENCE TO SERVE A TERM OF LIFE IN THE CUSTODY OF THE MISSISSIPPI DEPARTMENT OF CORRECTIONS District Attorney: Eleanor Faye Peterson Case Number: 04-1233 |
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| Party Name: | Attorney Name: | |||
| Appellant: | CHICO CRAFT |
WILLIAM R. LABARRE
VIRGINIA LYNN WATKINS |
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| Appellee: | STATE OF MISSISSIPPI | OFFICE OF THE ATTORNEY GENERAL BY: W. DANIEL HINCHCLIFF |
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Synopsis provided by:  If you are interested in subscribing to the weekly synopses of all Mississippi Supreme Court and Court of Appeals hand downs please contact Tammy Upton in the MLI Press office. |
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| Topic: | Murder - Deliberate design instruction - Sufficiency of evidence - Mistrial |
| Summary of the Facts: | Chico Craft was convicted of murder and was sentenced to a term of life. He appeals. |
| Summary of Opinion Analysis: | Issue 1: Deliberate design instruction Craft argues that two jury instructions on deliberate design were in hopeless conflict. Craft submitted one of the instructions of which he now complains. In addition, the jury instructions were not in conflict and did not preclude a finding of manslaughter. The jury was specifically told that deliberate design could not be formed at the same time as the fatal act. Issue 2: Sufficiency of evidence Craft argues there was insufficient evidence to support his murder conviction, because there was no evidence of deliberate design. Deliberate design connotes a prior design to kill. Deliberate design may be inferred from the circumstances, such as the use of a deadly weapon. There was sufficient evidence to support a finding of deliberate design. After Craft knocked the victim on the couch, Craft went to the nearby table to retrieve the knife. He returned to the couch and stabbed her. Besides a total of six stab wounds, the victim sustained many other cuts and abrasions, indicating that they struggled at some point while he had the knife. There was sufficient evidence for the jury to find that, before Craft slashed the victim’s throat, he had appreciable time to plan, and did in fact plan, to kill her. Issue 3: Mistrial Craft argues that the court should have granted a mistrial after a spectator’s emotional outburst disrupted trial. Outside influences must be eliminated if possible and minimized otherwise or the verdict rendered is questionable and a mistrial is appropriate. Here, the trial court immediately sent the jury out and restored order to the courtroom. There was no further outburst. It appears the trial court took prompt preventative action. Further, Craft did not feel the need to request a curative instruction after denial of the mistrial. |
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