Adams v. State
| Docket Number: | 2009-KA-01560-COA Linked Case(s): 2009-KA-01560-COA |
|
| Court of Appeals: |
Opinion Link Opinion Date: 02-08-2011 Opinion Author: Maxwell, J. Holding: Affirmed. |
|
| Additional Case Information: |
Topic: Murder - Miranda rights - Defense theory - M.R.E. 404(b) - M.R.E. 403 - M.R.E. 401 - Jury instruction - Sufficiency of evidence 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 |
|
| Trial Court: |
Date of Trial Judgment: 08-27-2009 Appealed from: CLARKE COUNTY CIRCUIT COURT Judge: LESTER F. WILLIAMSON, JR. Disposition: CONVICTED OF MURDER AND SENTENCED TO LIFE IN THE CUSTODY OF THE MISSISSIPPI DEPARTMENT OF CORRECTIONS Case Number: 2008-105 |
|
| Party Name: | Attorney Name: | Brief(s) Available: | ||
| Appellant: | Riley Lafate Adams a/k/a Riley Lafayete Adams |
GEORGE T. HOLMES, LESLIE S. LEE |
|
|
| Appellee: | State of Mississippi | OFFICE OF THE ATTORNEY GENERAL: BILLY L. GORE |
|
|
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. |
|
| Topic: | Murder - Miranda rights - Defense theory - M.R.E. 404(b) - M.R.E. 403 - M.R.E. 401 - Jury instruction - Sufficiency of evidence |
| Summary of the Facts: | Riley Adams was convicted of murder and sentenced to life. He appeals. |
| Summary of Opinion Analysis: | Issue 1: Miranda rights Adams argues his final statement to law enforcement, which he penned by hand, was involuntary because law enforcement did not renew previously given Miranda warnings. The State has the burden to prove beyond a reasonable doubt that a confession was voluntary. This burden is met and prima facie case made out by testimony of an officer, or other persons having knowledge of the facts, that the confession was voluntarily made without threats, coercion, or offer of reward. A criminal defendant need not be advised of his rights every time there is a brief pause in questioning. Miranda simply requires that if the individual indicates in any manner, at any time prior to or during questioning, that he wishes to remain silent, the interrogation must cease. While the passage of time between a defendant’s receipt of his Miranda rights and his confession may be a factor in determining the voluntariness of the confession, the passage of time is not itself necessarily sufficient to render Miranda warnings ineffective. In this case, Adams’s final statement was not rendered involuntary by the investigator’s failure to re-issue Miranda warnings. During the two days prior to the complained of confession, Adams was advised of his rights at least three times, twice orally, and once by a written waiver form signed by Adams. Further, the investigator testified that he reminded Adams of the prior warnings before obtaining each subsequent statement. Therefore, there was no error in the circuit court’s admission of Adams’s final statement to law enforcement. Issue 2: Defense theory Adams argues that the circuit court prevented him from presenting his theory of defense—that during his suicide attempt, the victim tried to wrestle his gun away from him, leading to the accidental discharge that killed the victim. The State objected based on relevancy when Adams attempted to offer testimony about his prior suicide attempts. Though not mentioned by either party, this issue concerns M.R.E. 404(b). To be admissible under Rule 404(b), the evidence must be relevant to prove a material issue other than the defendant’s character and the probative value of the evidence must outweigh the prejudicial effect under M.R.E. 403. M.R.E. 401 defines “relevant evidence” as that having any tendency to make the existence of any fact that is of consequence to the determination of the action more probable or less probable than it would be without the evidence. Adams’s proffered testimony is too vague and unspecific to support admission. Adams also failed to identify any specific time frames when the alleged suicide attempts occurred. Thus, the circuit court did not err in excluding Adams’s vague testimony concerning prior suicide attempts. Issue 3: Jury instruction Adams argues the circuit court erred in denying one of his proposed jury instructions. A criminal defendant is entitled to jury instructions that present his theory of the case even if the supporting evidence is weak, inconsistent, or of doubtful credibility. However, the court may refuse an instruction which incorrectly states the law, is covered fairly elsewhere in the instructions, or is without foundation in the evidence. Voluntary intoxication is not a defense in Mississippi. Adams’ proposed instruction gives the impression that Adams’s intoxication, regardless of the reason for it, is a defense. Because this is not the law, there was no abuse of discretion in the circuit court’s denial of the instruction. Issue 4: Sufficiency of evidence Adams argues the verdict was not supported by legally sufficient evidence or is against the weight of the evidence. There is ample evidence to sustain Adams’s conviction. In one typewritten statement, Adams admitted that he shot the victim. It indicates that he and the victim got into an argument. And after working on a puzzle, he walked to a cabinet, removed his pistol, and proceeded to the bedroom. He sat on the bed, cocked his .22-caliber revolver, then shot the victim in the neck. Adams’s handwritten statement is similar. These two incriminating statements, which the jury was free to accept among the many contradictory ones, strongly support the State’s position that Adams acted with deliberate design. Viewing the evidence in the light most favorable to the State, rational jurors could have found Adams guilty. |
Home | Terms of Use | About the JDP | Feedback | Using JDP | MC Law Library | Mississippi Supreme Court
