Edmonds v. State
| Docket Number: | 2004-CT-02081-SCT Linked Case(s): 2004-CT-02081-SCT ; 2004-CT-02081-SCT ; 2004-KA-02081-COA ; 2004-KA-02081-COA |
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| Supreme Court: | Opinion Link Opinion Date: 05-10-2007 Opinion Author: Waller, P.J. Holding: Reversed and Remanded |
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| Additional Case Information: |
Topic: Capital murder - Daubert hearing - M.R.E. 702 - Expert opinion - Privilege against self-incrimination - M.R.E. 804 - Statement against interest - Exclusion of videotape - M.R.E. 403 - Right to fundamentally fair trial Judge(s) Concurring: Smith, C.J., Diaz, P.J., Carlson, Graves and Randolph, JJ. Judge(s) Concurring Separately: Diaz, P.J. Joined by Graves, J. Randolph, J. Joined by Waller, P.J., and Carlson, J. Dissenting Author : Easley, J. Nature of the Case: CRIMINAL - FELONY Writ of Certiorari: Granted Appealed from Court of Appeals |
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| Trial Court: |
Date of Trial Judgment: 07-24-2004 Appealed from: Oktibbeha Circuit Court Judge: James Kitchens, Jr. Disposition: Tyler Edmonds was convicted of the capital murder of Joey Fulgham and sentenced to a term of life in the custody of the Mississippi Department of Corrections. District Attorney: Forrest Allgood Case Number: 2003-0132-CR |
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| Note: | This opinion finds that Tyler was denied a constitutionally fair trial, reverse the judgments of the Court of Appeals and of the Circuit Court of Oktibbeha County and remand this case to the circuit court for a new trial in accordance with this opinion. | |
| Party Name: | Attorney Name: | |||
| Appellant: | Tyler Edmonds |
Jim Waide |
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| Appellee: | State of Mississippi | Office of the Attorney General |
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| Topic: | Capital murder - Daubert hearing - M.R.E. 702 - Expert opinion - Privilege against self-incrimination - M.R.E. 804 - Statement against interest - Exclusion of videotape - M.R.E. 403 - Right to fundamentally fair trial |
| Summary of the Facts: | The motion for rehearing is denied, these opinions are substituted for the original opinions. Tyler Edmonds was convicted of capital murder for participating with his sister, Kristi, in the murder of Kristi’s husband. He was sentenced to a term of life. He appealed, and the Court of Appeals affirmed. The Supreme Court granted certiorari. |
| Summary of Opinion Analysis: | Issue 1: Daubert hearing When determining admissibility of expert testimony under M.R.E. 702, the court considers whether the expert opinion is based on scientific knowledge (reliability); whether the expert opinion will assist the trier of fact to understand or determine a fact in issue (relevance); whether the theory can be, and has been, tested; whether the theory has been published or subjected to peer review; any known rate of error; and the general acceptance that the theory has garnered in the relevant expert community. The circuit court did not err in excluding the testimony of Allison Redlich, Ph.D., concerning involuntariness of confessions because, during the extensive Daubert hearing, Dr. Redlich herself admitted that her theories could not be empirically tested. Issue 2: Expert testimony Stephen Hayne, M. D., conducted the autopsy on the victim’s body and testified at trial as to the cause of death. During his testimony, Dr. Hayne espoused a two-shooter theory almost to the exclusion of a single shooter theory. Tyler’s attorney objected to the testimony, arguing that such testimony was beyond Dr. Hayne’s area of expertise. While Dr. Hayne is qualified to proffer expert opinions in forensic pathology, a court should not give such an expert carte blanche to proffer any opinion he chooses. There was no showing that Dr. Hayne’s testimony was based, not on opinion or speculation, but rather on scientific methods and procedures. Therefore, the testimony pertaining to the two-shooter theory should not have been admitted. Tyler’s substantial rights were affected by Dr. Hayne’s conclusory and improper testimony. Dr. Hayne’s two-shooter testimony impermissibly (because it was not empirically proven) bolstered the State’s theory of the case that Kristi helped Tyler to fire the gun. However, a full-scale Daubert hearing is not required when an expert witness proffers an “off-the-cuff” opinion like Dr. Hayne did. Issue 3: Privilege against self-incrimination Even though Tyler included Kristi Fulgham on his witness list and issued a subpoena for her to appear, he never called her to the stand. Instead, he attempted to introduce evidence of some of Kristi’s statements to Kristi and Tyler’s father, which tended to show motive on her part. The circuit court ruled that this evidence was inadmissible hearsay. Tyler argues that this ruling was error because the statements were admissible as statements against interest under M.R.E. 804. In all of the preliminary proceedings and during the trial, Kristi Fulgham’s defense counsel was present to insure that she would not be prejudiced in any way. Her defense counsel filed a motion to prevent Kristi from being called to testify, and her counsel also appeared at both a pretrial hearing and at trial to state for the record that Kristi would invoke her Fifth Amendment right. Kristi was charged with capital murder in the murder of her husband – the same crime with which Tyler was charged. Kristi’s attorney asserted to the circuit court that, if called, she would invoke her privilege against self-incrimination. Tyler made a proffer of the statements which he wished to introduce as statements against interest, so the circuit court knew what information Tyler wished to elicit from Kristi. However, since Kristi was never called as a witness and there is no specific ruling by the circuit court to review, the issue of what is required to assert the Fifth Amendment will not be addressed. Regardless of Kristi’s availability as a witness, the circuit court erred in excluding the proffered testimony of Tyler’s father as inadmissible hearsay. Under M.R.E. 804, for a statement against interest to admissible, the statement must be against the witness’s penal interest. Although the remarks did not amount to a clear confession to a crime, they would have probative value in the State’s case against Kristi. The statements clearly indicate her intention to murder her husband and would be probative in the State’s case against Kristi for Joey’s murder. Therefore, they are sufficiently against Kristi’s penal interest to fall under Rule 804. Corroboration as required by Rule 804(b)(3) is not required to be absolute, and the sufficiency of the corroboration must be assessed in the light of the importance of the evidence and the offeror's fundamental constitutional right to present evidence. The testimony was sufficiently trustworthy because the witness was both Kristi and Tyler’s father. Surely, he had a significant reason not to inculpate Kristi, and it is reasonable to assume that he would not testify that she made the statements unless she really did make the statements. Moreover, his statement is corroborated by other evidence. Issue 4: Exclusion of videotape Tyler attempted to offer in his defense a video of Kristi and her husband’s appearance on the Montel Williams Show. The video would have been offered as evidence of Kristi’s motive to murder her husband. On the show, she admitted to having an affair with her husband’s best friend and subsequently having his friend’s child while the two were married. The circuit court excluded the video on the grounds that it would violate M.R.E. 403. This ruling was erroneous. Since Tyler was given a separate trial, the evidence is in no way unfairly prejudicial to Kristi because the evidence would not have been presented to her jury. Issue 5: Right to fundamentally fair trial A criminal defendant is entitled to present his defense to the finder of fact, and it is fundamentally unfair to deny the jury the opportunity to consider the defendant’s defense where there is testimony to support the theory. Here, the only direct evidence that Tyler was involved in the murder was Kristi’s allegations that Tyler killed the victim and Tyler’s disputed confession. Tyler had absolutely no motive to kill the victim other than to please Kristi. The circuit court’s refusal to allow testimony from a witness about Kristi wanting to kill her husband and the circuit court’s refusal to allow the jury to see the Montel Williams videotape clearly prejudiced Tyler. |
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