Stephens v. State
| Docket Number: | 2003-KA-02549-SCT Linked Case(s): 2003-KA-02549-SCT |
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| Supreme Court: | Opinion Link Opinion Date: 06-16-2005 Opinion Author: Graves, J. Holding: Affirmed |
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| Additional Case Information: |
Topic: Murder - Cameras in the courtroom - Mississippi Rules of Electronic and Photographic Coverage - Corpus delicti - Sufficiency of evidence - M.R.E. 801(d)(2) - Admission by party-opponent - Admission of confession - Circumstantial evidence instruction - Confidential informant Judge(s) Concurring: Smith, C.J., Waller, P.J., Easley, Carlson and Randolph, JJ. Non Participating Judge(s): Cobb, P.J., Diaz and Dickinson, JJ. Procedural History: Jury Trial Nature of the Case: CRIMINAL - FELONY |
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| Trial Court: |
Date of Trial Judgment: 09-15-2003 Appealed from: Forrest County Circuit Court Judge: Jess H. Dickinson Disposition: Stephends was convicted of murder, in violation of Section 97-3-19 of the Mississippi Code of 1972. Following the jury’s verdict, the trial judge sentenced Stephanie to life imprisonment in the custody of the Mississippi Department of Corrections. District Attorney: Jon Mark Weathers Case Number: 03-104CR |
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| Note: | Appellant's Motion to Supplement the Record is granted | |
| Party Name: | Attorney Name: | |||
| Appellant: | Stephanie K. Stephens |
RAY T. PRICE |
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| Appellee: | State of Mississippi | OFFICE OF THE ATTORNEY GENERAL: W. GLENN WATTS |
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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 - Cameras in the courtroom - Mississippi Rules of Electronic and Photographic Coverage - Corpus delicti - Sufficiency of evidence - M.R.E. 801(d)(2) - Admission by party-opponent - Admission of confession - Circumstantial evidence instruction - Confidential informant |
| Summary of the Facts: | Stephanie Stephens was convicted of murder and was sentenced to life imprisonment. She appeals. |
| Summary of Opinion Analysis: | Issue 1: Cameras in the courtroom Stephanie argues that the court violated Rule 4 of the Mississippi Rules of Electronic and Photographic Coverage by allowing media into the courtroom during her trial. The record shows that Stephanie never made a contemporaneous objection to allowing CBS into the courtroom during her trial. Where no contemporaneous objection is made, the alleged error is waived. Stephanie argues that the placement of CBS’s cameras in the courtroom not only violated Rule 4, but severely abrogated her right to a fair trial. Stephanie fails to demonstrate how the placement of the cameras was so intrusive as to disrupt the proceedings. The Rules vest the presiding judge with a wide range of discretion with regard to the location and placement of the media equipment. A review of CBS’s footage reveals that the equipment used did not produce any unreasonably distracting sounds or light. All running wires were taped to the floor throughout the trial. The footage did not include the identity of any of the seated jurors nor the jury selection process. In addition to following the Rules, during the pre-trial hearing, the trial court instituted additional safeguards to insure that Stephanie received a fair and impartial trial. The presence of the media equipment was not so intrusive that the integrity of the proceeding was compromised. Also, Stephanie fails to set forth any prejudicial effect the placement of the cameras had upon her trial. When a party claims a violation of the Rules, it is incumbent upon that party to come forward with evidence in support of their claim. Stephanie also argues that any protections previously afforded by the order changing venue were eliminated. Not only does the record show that the jury was sequestered throughout the duration of the trial, but Stephanie offers no support to suggest that this jury would have reached a different result but for the presence of the media. Issue 2: Corpus delicti Stephanie argues that the State failed to prove that her husband was actually murdered. Instead, she believes sufficient, credible evidence existed to prove that he committed suicide. In order to show that a crime has actually been committed, it is necessary to prove the existence of a certain act or result forming the basis of a criminal charge and the State must prove the existence of criminal agency as the cause of this act or result. Where a defendant confesses to a crime, the confession itself is not sufficient to support a felony conviction unless it is corroborated by independent evidence of the corpus delicti. However, where there is a confession, much slighter evidence is required to prove corpus delicti. When coupled with other evidentiary proof offered by the State, Stephanie’s confession to a friend was sufficient to establish the corpus delicti of murder. The record reveals numerous facts which indicate Stephanie’s opportunity, ability, knowledge and motive to commit the crime charged. Issue 3: Sufficiency of evidence Stephanie argues that her conviction was based wholly upon circumstantial evidence, and as such, the evidence was legally insufficient to support her conviction. A circumstantial evidence case is one in which there is neither an eyewitness nor a confession to the crime. This case is not solely based upon circumstantial evidence in that the defendant confessed to the crime charged. The testimony by Stephanie’s friend was clearly admissible pursuant to M.R.E. 801(d)(2) as an admission by a party-opponent. Issue 4: Admission of confession Stephanie argues that the testimony concerning the confession should have been stricken and given no credibility whatsoever, because the witness had a motive to fabricate the confession. The court did not abuse its discretion in allowing the jury to consider the testimony of the witness. As the trial court correctly pointed out, the witness had personal knowledge of the events upon which her testimony was based. Also, her testimony was relevant to the issue of whether Stephanie committed the murder. The jury was furnished with the task of weighing this testimony along with that of all the other witnesses. Issue 5: Circumstantial evidence instruction Stephanie argues that the court erred in refusing her circumstantial evidence instruction. Granting a circumstantial evidence instruction would have been improper since the testimony concerning the confession raised the proof to more than circumstantial evidence. Issue 6: Confidential informant Stephanie argues that the State withheld exculpatory material, i.e., the identity of a confidential informant. The defendant must show that the State possessed favorable evidence to the defendant. The record does not establish that this informant was a witness to the crime for which Stephanie was tried. Also, the informant was never a witness for the prosecution at any proceeding in the instant action. Additionally, the trial court interviewed the informant and discovered that the informant received information from overhearing a conversation between two people the informant did not know. There was no indication that the identity of the informant was relevant to the issues presented in the instant action. |
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