Singleton v. State
| Docket Number: | 2007-KA-00911-COA Linked Case(s): 2007-KA-00911-COA |
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| Court of Appeals: |
Opinion Link Opinion Date: 10-21-2008 Opinion Author: BARNES, J. Holding: Affirmed |
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| Additional Case Information: |
Topic: Robbery & Capital murder - Out-of-court statement of deceased co-defendant Judge(s) Concurring: King, C.J., Lee and Myers, P.JJ., Irving, Chandler, Griffis, Ishee, and Carlton, JJ. Non Participating Judge(s): ROBERTS, J. Procedural History: Jury Trial Nature of the Case: CRIMINAL - FELONY |
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| Trial Court: |
Date of Trial Judgment: 05-02-2007 Appealed from: Clarke County Circuit Court Judge: Lester F. Williamson Disposition: CONVICTION OF COUNT I, CAPITAL MURDER, AND COUNT II, ROBBERY, AND SENTENCE OF LIFE IMPRISONMENT IN THE CUSTODY OF THE MISSISSIPPI DEPARTMENT OF CORRECTIONS WITHOUT ELIGIBILITY FOR PAROLE District Attorney: Bilbo Mitchell Case Number: 2006-53 |
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| Party Name: | Attorney Name: | Brief(s) Available: | ||
| Appellant: | SHAWN MICHAEL SINGLETON |
GLENN S. SWARTZFAGER |
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| Appellee: | STATE OF MISSISSIPPI | OFFICE OF THE ATTORNEY GENERAL BY: STEPHANIE BRELAND WOOD | ||
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: | Robbery & Capital murder - Out-of-court statement of deceased co-defendant |
| Summary of the Facts: | Shawn Singleton was convicted of robbery and capital murder. He was sentenced to life imprisonment without parole. He appeals. |
| Summary of Opinion Analysis: | Singleton argues that the court erred when it allowed the State to refer to the statement of a co-defendant who passed away before Singleton’s trial, because his constitutional right to confront the witness was violated. Out-of-court statements by witnesses that are testimonial in nature are not allowed under the Confrontation Clause unless the witness is unavailable and the defendant had a prior opportunity to cross-examine the witness. Statements of a testimonial nature have been held to include police interrogations. In this case, testimony at trial showed law enforcement officials interviewed the co-defendant twice, and she provided the same information in both interviews. However, as the defense concedes, her statements were never entered into evidence, either in whole or in part. Instead, the information in her statements was compared to Singleton’s statement that was admitted into evidence. Her statements were not used to shift the blame to Singleton, but to corroborate his own statement. Corroborating Singleton’s statement through his co-defendant’s out-of-court statement was a violation of Singleton’s constitutional right to confront the co-defendant. However, a violation of the Confrontation Clause can be subject to harmless-error analysis. Violation of an accused’s constitutional rights may be deemed harmless beyond a reasonable doubt where the weight of the evidence against the accused is overwhelming. There is overwhelming evidence of Singleton’s guilt. Most importantly, Singleton’s own statement confessing to robbing the victim and stabbing him in the abdomen with a screwdriver was entered into evidence. While the wounds Singleton admitted to inflicting on the victim were not fatal, aiding and abetting his co-defendant in her crimes is sufficient to convict him of capital murder and robbery if the jury found his guilt beyond a reasonable doubt. Because of the overwhelming weight of the evidence against Singleton, allusions to the deceased co-defendant’s statement was harmless error. |
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