Edmonds v. State


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Docket Number: 2004-KA-02081-COA
Linked Case(s): 2004-CT-02081-SCT ; 2004-CT-02081-SCT ; 2004-CT-02081-SCT ; 2004-KA-02081-COA

Court of Appeals: Opinion Date: 01-31-2006
Opinion Author: Irving, J.
Holding: Affirmed

Additional Case Information: Topic: Murder - Voluntariness of confession - False confession expert testimony - M.R.E. 702 - Daubert standard - Admissibility of forensic pathologist’s testimony - Statement of deceased witness - M.R.E. 804(b)(5) - Defense theory - Hearsay statement - M.R.E. 804(b)(3) - Admission of videotape - M.R.E. 403 - Challenges for cause - Section 13-5-79 - Sentence instruction - Transfer to youth court - Section 43-21-151(1) - Automatic life sentence - Cautionary instruction - Recantation testimony - Closing the suppression hearing
Judge(s) Concurring: Myers, P.J., Griffis, Ishee and Roberts, JJ.
Judge(s) Concurring Separately: Lee, P.J., Joined by Griffis and Roberts, JJ.
Non Participating Judge(s): Southwick and Chandler, JJ.
Concur in Part, Dissent in Part 1: Barnes, J.
Concur in Part, Dissent in Part Joined By 1: King, C.J.
Procedural History: Jury Trial
Nature of the Case: CRIMINAL - FELONY
Appealed from Court of Appeals

Trial Court: Date of Trial Judgment: 07-24-2004
Appealed from: Oktibbeha County Circuit Court
Judge: James T. Kitchens, Jr.
Disposition: The judgment of the Oktibbeha County Circuit Court of conviction of murder and sentence of life in the custody of the Mississippi Department of Corrections is affirmed.
Case Number: 2003-0132-CR

Note: This opinion was reversed by the Mississipip Supreme Court on May 10, 2007.

  Party Name: Attorney Name:  
Appellant: Tyler Edmonds








 

Appellee: State of Mississippi  

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Topic: Murder - Voluntariness of confession - False confession expert testimony - M.R.E. 702 - Daubert standard - Admissibility of forensic pathologist’s testimony - Statement of deceased witness - M.R.E. 804(b)(5) - Defense theory - Hearsay statement - M.R.E. 804(b)(3) - Admission of videotape - M.R.E. 403 - Challenges for cause - Section 13-5-79 - Sentence instruction - Transfer to youth court - Section 43-21-151(1) - Automatic life sentence - Cautionary instruction - Recantation testimony - Closing the suppression hearing

Summary of the Facts: Tyler Edmonds was convicted of murder and sentenced to life. He appeals.

Summary of Opinion Analysis: Issue 1: Voluntariness of confession Edmonds argues that his age (thirteen), his lack of experience with law enforcement interrogation, the removal of his mother from the room during the interrogation, and the fact that the police officers allegedly used his half-sister to pressure him into confessing, caused his confession to be unreliable, involuntary, and inadmissible. The record shows that, prior to confessing, Edmonds, along with his mother, signed Miranda waiver of rights forms. There is no testimony that either of them asked for an attorney or for the interrogation to stop. Furthermore, the videotape interview was preceded by a second Miranda waiver of rights form, which was signed by Edmonds. Under existing law and precedent, the same standards for the voluntariness of Edmonds’s confession apply as those for any other confession. Therefore, there is no merit to the argument that Edmonds’ mother should have been present while he was being questioned about his involvement in the murder. Regarding pressure from his half-sister, if she had applied the pressure that Edmonds would have the court believe was applied, at least one of his statements would have been more favorable to her. In addition, Edmonds did not waiver in his confession to his mother that he and his half-sister did the murder. The exchange with his mother is extremely compelling, and is indicative of the fact that Edmonds voluntarily confessed without any undue pressure, coercion, or threats from law enforcement officers, his half-sister, or anyone else. Issue 2: Expert testimony Edmonds argues that the court erred in excluding testimony from his expert in the study of false confessions about the characteristics of false confessions and their alleged prevalence among juveniles. M.R.E. 702 recognizes that the Daubert rule, as modified, provides a superior analytical framework for evaluating the admissibility of expert witness testimony. Under that rule, the trial court’s job is to perform a two-pronged inquiry: whether the expert’s testimony would be relevant, and whether the proposed testimony is reliable. As to the first factor, whether the theory has or can be tested, the trial court in this case accurately found that the expert herself had already admitted that the theory could not ethically be tested, and therefore would not be tested at all. In evaluating the second factor, whether the theory has been subjected to peer review and publication, the trial court found that, although there are a number of publications regarding false confessions, the proponents of the field of expert testimony regarding false confessions appears to be a small group. The trial court also found that the third Daubert factor, known or potential rate of error, weighed against the admissibility of the testimony since the expert herself testified that there is no way to discern a possible rate of error in the field of false confessions, because the theory cannot ethically be tested. In analyzing the final Daubert factor, general acceptance in the relevant scientific community, the court looked to how much acceptance the theory had gained in terms of admissibility in other courts and held that it could not say that expert opinion in the field of coerced or false confessions is widely accepted within the scientific community. Given this analysis, the court did not abuse its discretion in finding that the expert’s testimony did not meet the standards for admissibility of expert testimony. Although the Mississippi Supreme Court has not explicitly ruled on the admissibility of expert testimony about false confessions, the Court did question the validity of such testimony in Thorson v. State, 895 So. 2d 85, 123 (¶89) (Miss. 2004). Issue 3: Admissibility of forensic pathologist’s testimony Edmonds argues that Dr. Hayne’s opinion was that two persons simultaneously pulled the trigger of the gun that fired the shot that killed the victim which required a Daubert hearing. However, the record shows that the State did not ask Dr. Hayne whether his autopsy findings were consistent with two people pulling the trigger. Moreover, Dr. Hayne did not testify to such a finding. In fact, it was the defense which brought up the matter of the two-person-trigger firing scenario. Also, it is clear that the point which Dr. Hayne was attempting to make is that, given Edmonds’ testimony that Edmonds did not aim the weapon at anything, it was more likely than not that another person assisted. Dr. Hayne, as a qualified forensic pathologist, was competent to answer the question asked him by the State, without being subjected to a Daubert hearing. Edmonds also argues that the court erred in allowing Dr. Hayne’s testimony because the State failed to disclose to him that Dr. Hayne would testify that two people pulled the trigger of the murder weapon. As already noted, that was not Dr. Hayne’s testimony on direct examination. Therefore, there was no obligation to disclose anything. Issue 4: Statement of deceased witness Edmonds argues that the court erred in refusing to admit the statement of a witness who died before the trial began. The witness had previously given the police a statement, saying that Edmonds’ half-sister had asked her for a gun to shoot a dog. Edmonds argues that the statement should have been admissible under M.R.E. 804(b)(5). Since another witness testified to virtually the same information as was contained in the deceased witness’s statement to the police, the statement was not more probative on the point than the testimony at trial and was properly denied under Rule 804(b)(5). Issue 5: Defense theory Edmonds argues that the court erred in not allowing him to introduce allegedly crucial evidence which would have supported his defense, i.e., testimony from his father and videotape from the Montel Williams television show which would have helped to reveal his half-sister’s desire and motive to kill her husband. Statements made by Edmonds’ half-sister to their father were hearsay. Because the half-sister’s unavailability was never proven, her statements do not fall within the hearsay exception of M.R.E. 804(b)(3). Moreover, there were no corroborating circumstances clearly indicative of the trustworthiness of her statement. Edmonds also argues that even if the trial court disallowed the statements on the basis of hearsay, the hearsay rule cannot be used to preclude a criminal defendant from introducing the fact that another has admitted to the crime of which the defendant stands accused. However, the statement in this case is not a confession but only a statement made before the murder that she wanted her husband dead. With regard to the videotape, the trial court properly conducted a M.R.E. 403 analysis. The videotape was unduly prejudicial and any probative value was outweighed by the potential to confuse the issues or mislead the jury. Issue 6: Challenges for cause Edmonds argues that the court erred in excluding four jurors because the court believed that the potential jurors would consider his age. Section 13-5-79 provides that any juror shall be excluded if the court is of the opinion that he cannot try the case impartially, and the exclusion shall not be assignable for error. The trial court did not abuse its discretion in excluding these potential jurors. Issue 7: Sentence instruction Edmonds argues that the jurors might have been misled into believing that, due to his age, he could receive a sentence less than life. Under current Mississippi law, it is improper to argue the sentence that a defendant might receive before a jury. Under the facts of this case, it would have been improper for the court to have allowed Edmonds’ attorneys to inform the jury that Edmonds would receive a mandatory life sentence if convicted of murder. The only purpose of such a comment would have been to incite the passions of the jury and encourage jury nullification. Therefore, the court did not abuse its discretion in not allowing Edmonds to inform the jury that he could receive a mandatory life sentence if convicted. Issue 8: Transfer to youth court Edmonds argues that the court erred in refusing to transfer his case to youth court. Section 43-21-151(1) dictates that capital murder crimes come under the original jurisdiction of the circuit court. Therefore, the Oktibbeha County Circuit Court had original jurisdiction over Edmonds’ case. The Mississippi Code does allow the transfer of such cases to youth court, under section 43-21-159(4), but such transfer is optional and is at the circuit court’s discretion. In the present case, the trial judge performed an extensive analysis of what would be in both Edmonds’ best interest, and the best interest of justice. Issue 9: Automatic life sentence Edmonds argues that the automatic life sentence imposed upon him is unconstitutional, because it does not allow the trial court any discretion to take into account his particular circumstances and he did not have the opportunity to present mitigating factors. The United States Supreme Court held in Chapman v. United States, 500 U.S. 453, 466-67 (1991), that a sentence does not need to take into account individual degrees of culpability to be constitutional. Despite the fact that no discretion is given the trial court by the statute, Edmonds’ sentence is still constitutional, and the court did not err in sentencing Edmonds to life. Issue 10: Cautionary instruction Edmonds argues that the court erred in refusing to grant a proposed jury instruction that confessions by juveniles should be considered with caution. The Mississippi Supreme Court has held that it is not reversible error for a court to refuse to give an instruction cautioning a jury that it must regard the testimony of a juvenile with particular caution. The jury in this case was adequately instructed regarding the credibility with which it should view Edmonds’ confession. Issue 11: Recantation testimony Edmonds argues that it was error on the part of the court to refuse to allow the defense to produce evidence that he had retracted his confession. However, the record shows that the court did not even rule on the admission of the recantation videotape. Additionally, Edmonds testified to the substance of his recantation on direct examination, and the jury was eventually told that he had recanted his videotaped confession. Issue 12: Closing the suppression hearing Edmonds argues that the court erred in excluding the press and the public from his suppression hearing. In Waller v. Georgia, 467 U.S. 39 (1984), the U.S. Supreme Court stated that the party seeking to close the hearing must advance an overriding interest that is likely to be prejudiced, the closure must be no broader than necessary to protect that interest, the trial court must consider reasonable alternatives to closing the proceeding, and it must make findings adequate to support the closing. Here, the court properly determined that the only viable option left to the court was to close the suppression hearing to the press and public in order to prevent any further pre-trial publicity and to protect the co-defendant’s constitutional right to a fair and impartial trial. Furthermore, according to the Rules for Electronic and Photographic Coverage of Judicial Proceedings, electronic coverage of matters such as suppression hearings are left to the judge’s discretion.


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