Haynes v. State
| Docket Number: | 2005-KA-00722-SCT Linked Case(s): 2005-KA-00722-SCT |
|
| Supreme Court: | Opinion Link Opinion Date: 06-08-2006 Opinion Author: Smith, C.J. Holding: Affirmed |
|
| Additional Case Information: |
Topic: Murder, Sexual battery & First degree arson - Transfer of venue - Suppression of confession - Sufficiency of evidence Judge(s) Concurring: Easley and Carlson, JJ. Non Participating Judge(s): Diaz, J. Dissenting Author : Dickinson, J. Dissent Joined By : Waller and Cobb, P.JJ., and Graves, J. Concurs in Result Only: Randolph, J. Procedural History: Jury Trial Nature of the Case: CRIMINAL - FELONY |
|
| Trial Court: |
Date of Trial Judgment: 02-02-2005 Appealed from: Attala County Circuit Court Judge: Clarence E. Morgan, III Disposition: Haynes was tried and found guilty of murder, sexual battery, and first degree arson, and sentenced to consecutive sentences of life for murder, thirty years for sexual battery, and twenty years for first degree arson. District Attorney: DOUG EVANS Case Number: 2004-00085-CR |
|
| Party Name: | Attorney Name: | |||
| Appellant: | Justin Haynes |
EDWARD C. FENWICK |
||
| Appellee: | State of Mississippi | OFFICE OF THE ATTORNEY GENERAL: JOSE BENJAMIN SIMO |
|
|
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, Sexual battery & First degree arson - Transfer of venue - Suppression of confession - Sufficiency of evidence |
| Summary of the Facts: | Justin Haynes was found guilty of murder, sexual battery, and first degree arson, and sentenced to consecutive sentences of life for murder, thirty years for sexual battery, and twenty years for first degree arson. He appeals. |
| Summary of Opinion Analysis: | Issue 1: Transfer of venue Haynes argues that the trial should not have been transferred to Rankin County, a county where black citizens constitute only seventeen percent of the demographic, as compared to Attala County, whose black citizens make up forty percent of the demographic. A defendant has no right to a change of venue to a jurisdiction with certain racial demographics. Here, the judge moved the trial to Rankin County, after considering factors such as where Haynes could obtain a fair and impartial trial, away from pretrial publicity. The circuit judge also considered courthouse facilities, proximity from the transferor county, and the location of witnesses. There was no abuse of discretion. Haynes also argues that the judge improperly denied his motion to quash the venire which was only twelve percent black, when Rankin County’s demographic is seventeen percent black. Haynes made no objection to the selection process, nor did he present any evidence indicating systematic exclusion of blacks in the jury-selection process. Thus, this argument is without merit. Issue 2: Suppression of confession Haynes argues that his confession was the result of police interrogation, and therefore was inadmissible. Once an accused has invoked his right to counsel, any statements given by the defendant in response to further police questioning are admissible only where the defendant initiated further discussions with the police and knowingly and intelligently waived the rights he had invoked. In this case, after invoking the right to counsel, Haynes admits to initiating conversation as to his bond and other matters, but argues he did not initiate a conversation as to the charges he was facing. This case is of first impression with regard to what constitutes “initiation” as to a conversation relating directly or indirectly to the investigation and conversation relating to routine incidents of the custodial relationship. Haynes asked to speak to the officer regarding what he terms “procedural matters,” including bond, scheduling, and a preliminary hearing. Those inquiries are matters relating to routine incidents of the custodial relationship. Therefore, Haynes’ questions did not initiate a conversation. Moreover, at no point in the officer’s testimony did he say Haynes asked other questions which evinced a willingness and a desire for a generalized discussion about the investigation. It was only after the officers’ questions, specifically, “if he wanted to tell us anything about the situation,” whether Haynes had told the truth, and what was bothering him, that Haynes gave his confession. However, the State argues that because Haynes received his Miranda rights and signed a waiver of those rights before the conversation took place between Haynes and the two officers, the trial court was correct in allowing Haynes’ confession into evidence. Even if Haynes knowingly, intelligently, and voluntarily waived his right, the waiver does not cure the violation. Adopting the State’s position would allow an officer to question a defendant subsequent to the invocation of counsel, where the defendant asked a question that is custodial in nature. Therefore, the circuit judge erred in admitting the confession into evidence. In order for a violation of a constitutional right to be held harmless, the Court must determine that the violation was harmless beyond a reasonable doubt. Without Haynes’ confession, the State submitted only circumstantial evidence establishing that Haynes’ actually set the fire which led to the victim’s death. Although DNA of the semen found on the victim’s body matched Haynes’ DNA indicating sexual battery, the State presented little concrete evidence actually showing Haynes was responsible for setting the fire. Without Haynes’ confession, the jury may have given different weight to the State’s evidence, and possibly in Haynes’ favor. Moreover, Haynes’ argument that another person may have played a role in the crime also constitutes a shift in the trial’s dynamic. Haynes originally told police that this person perpetrated the crime. However, the evidence against Haynes, disregarding his confession, is overwhelming and links him to the scene of the crime. Based on the large amount of evidence establishing Haynes’ culpability, the circuit judge’s admission of Haynes’ confession was harmless beyond a reasonable doubt. Issue 3: Sufficiency of evidence Haynes argues the evidence presented at trial is insufficient as a matter of law to warrant a conviction on the three counts of the indictment. Excluding Haynes’ confession, and considering only the evidence the State presented in the light most favorable to the State, there is sufficient evidence existed to convict Haynes of murder, sexual battery, and first degree arson. Haynes’ DNA and fingerprints were found at the crime scene, Haynes had detailed knowledge of the crime as related to the officers, alleging that another person was responsible for the crime, as well as other factors connecting Haynes to the crime. |
Home | Terms of Use | About the JDP | Feedback | Using JDP | MC Law Library | Mississippi Supreme Court
