Staten v. State
| Docket Number: | 2006-KA-01612-COA Linked Case(s): 2006-KA-01612-COA ; 2006-CT-01612-SCT |
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| Court of Appeals: |
Opinion Link Opinion Date: 01-29-2008 Opinion Author: CHANDLER, J. Holding: Affirmed |
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| Additional Case Information: |
Topic: Murder - Sufficiency of evidence - Psychiatric evaluation - URCCC 9.06 - Photographs - M.R.E. 103(a)(1) - Jury instructions - Depraved heart murder - Ineffective assistance of counsel - Disproportionate sentence Judge(s) Concurring: KING, C.J., LEE AND MYERS, P.JJ., IRVING, GRIFFIS, 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: 08-03-2006 Appealed from: Grenada County Circuit Court Judge: Clarence E. Morgan, III Disposition: CONVICTED OF MURDER AND SENTENCED TO LIFE IN THE CUSTODY OF THE MISSISSIPPI DEPARTMENT OF CORRECTIONS. District Attorney: Doug Evans Case Number: 2005-116 |
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| Party Name: | Attorney Name: | Brief(s) Available: | ||
| Appellant: | BRADFORD STATEN |
JAMES T. McCAFFERTY |
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| Appellee: | STATE OF MISSISSIPPI | OFFICE OF THE ATTORNEY GENERAL BY: LADONNA C. HOLLAND | ||
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 - Sufficiency of evidence - Psychiatric evaluation - URCCC 9.06 - Photographs - M.R.E. 103(a)(1) - Jury instructions - Depraved heart murder - Ineffective assistance of counsel - Disproportionate sentence |
| Summary of the Facts: | Bradford Staten was convicted of murder and sentenced to life. He appeals. |
| Summary of Opinion Analysis: | Issue 1: Sufficiency of evidence Staten argues that his guilt was not proven to the exclusion of all reasonable hypotheses consistent with innocence because he was the only person present when his wife received her fatal injuries, and he recounted that she fell and hit her head on the bedroom door. No evidence except Staten's own account of the incident supported his theory that his wife died as a result of striking her head on the door. From the evidence presented, a reasonable jury could have found from the physical evidence that Staten was lying about his wife having struck her head on the door and inferred from the circumstances to the exclusion of every reasonable hypothesis consistent with innocence that Staten caused death by inflicting the closed head injury and manually strangling his wife. Staten's account of how his wife died totally conflicted with the physical evidence. The evidence, viewed in the light most favorable to the prosecution, was that Staten repeatedly beat and stabbed his wife with a crutch and strangled her. These were willful acts likely to cause death or serious bodily injury and evinced a reckless indifference to the danger to human life from which malice may be inferred. Issue 2: Psychiatric evaluation Staten argues that the trial court erred by denying his motion for a mental evaluation to determine his competence to stand trial. According to URCCC 9.06, the trial court on its own motion or upon motion of an attorney shall order a mental evaluation if, before or during the trial, the trial court possesses reasonable ground to believe the defendant is incompetent to stand trial. In this case, the trial court held a hearing on Staten's motion for a mental evaluation to determine whether reasonable ground existed to believe Staten was incompetent to stand trial. Staten's mother testified that Staten had no history of mental illness, had a master's degree, and had been a counselor at a mental health center. She related that, after Staten's arrest, he became depressed, withdrawn, could not communicate, and was unable to recall names and telephone numbers. Defense counsel testified that Staten was unhelpful, was unresponsive to questions about what happened the night of the killing, and was unfocused on what the attorney needed him to focus on for adequate representation. Staten's former human resources manager testified that his file showed no history of mental illness, and a co-worker testified that Staten had never exhibited any mental problems. A deputy testified that, while Staten was upset on the night of the crime, he was able to understand and answer questions normally. A corrections officer, testified, from her observations at the jail, Staten was communicative and did not exhibit any signs of mental problems. Given this evidence, the court’s decision was not against the overwhelming weight of the evidence. Issue 3: Photographs Numerous photographs were admitted into evidence. Most of these photographs were of the crime scene. Staten argues that certain photographs were cumulative of each other and that the admission of so many photographs served to inflame the jury against him. Pursuant to M.R.E. 103(a)(1), Staten’s arguments concerning a number of the photographs are procedurally barred, because he failed to object to their admission. Photographs are admissible when they serve some legitimate, evidentiary purpose despite the fact that the photographs might arouse the jurors' emotions. With regard to the remaining photograph, the photograph aided the jury in ascertaining the circumstances of the victim's death and supplemented Dr. Hayne's testimony. Issue 4: Jury instructions Staten argues that the word "element" used in one of the instructions was a legal term confusing to a lay juror. This argument is procedurally barred because Staten did not specifically object at trial on this ground. Staten also argues that the word "lesser" improperly commented on the evidence and that the "unpleasant duty" language was impermissibly argumentative. Because the language that Staten complains of has been approved by the supreme court, this issue is without merit. Staten also argues that the language in another instruction was confusing because it juxtaposed the elements of depraved heart murder with the similar elements of manslaughter. However, the instruction accurately informed the jury how it was to structure its deliberations on the question of Staten's guilt or innocence of these crimes. Staten also argues that the court erroneously refused eleven of his proffered jury instructions. He argues that the evidence supported his proffered heat of passion manslaughter instructions. Though Dr. Hayne testified that the victim’s injuries were consistent with passion, there was absolutely no evidence supporting the theory that Staten's passion was the result of reasonable provocation. Also, the trial court properly refused two instructions as an improper attempt to define reasonable doubt. A number of the instructions submitted by Staten were covered fairly by other jury instructions. Staten argues that the court erred in failing to give an accident instruction. However, no such instruction was requested by Staten. Issue 5: Depraved heart murder Staten argues that the indictment which tracked the elements of deliberate design murder did not place him on notice of the depraved heart murder theory. As a matter of common sense, every murder done with deliberate design to effect the death of another human being is by definition done in the commission of an act imminently dangerous to others and evincing a depraved heart, regardless of human life. Therefore, this argument is without merit. Issue 6: Ineffective assistance of counsel Staten argues that trial counsel was deficient for putting on insufficient evidence supporting the request for a mental evaluation, failing to pursue an interlocutory appeal of the denial of a mental evaluation, failing to object to the admission of evidence including the CPR and first aid certification cards and photographs, failing to impeach the deputy with a prior inconsistent statement, asking the deputy questions on cross-examination that emphasized that a violent altercation occurred in several different places within the house, failing to cross-examine the DNA analyst concerning her identification of the victim's blood, allowing a prosecution witness to give narrative testimony, and failing to request an accident instruction. The record in this case, including the alleged deficiencies cited by Staten, does not affirmatively show ineffectiveness of constitutional dimensions. Rather, the record evinces that Staten was represented by two experienced defense attorneys. The decisions of which Staten complains fall within the presumption of trial strategy and reasonable professional assistance. Issue 7: Disproportionate sentence Staten argues that life imprisonment without the possibility of parole is too harsh a penalty under the circumstances of this case. The sentence for murder is imprisonment for life. Staten was convicted of murder and was sentenced to life imprisonment, not to life without the possibility of parole. |
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