Jones v. State
| Docket Number: | 2004-KA-00961-SCT Linked Case(s): 2004-KA-00961-SCT |
|
| Supreme Court: | Opinion Link Opinion Date: 06-30-2005 Opinion Author: Carlson, J. Holding: Affirmed |
|
| Additional Case Information: |
Topic: Murder - Expert testimony - M.R.E. 702 - Coroner’s report - M.R.E. 803(8) - Sufficiency of evidence Judge(s) Concurring: Smith, C.J., Waller and Cobb, P.JJ., Easley, Dickinson and Randolph, JJ. Non Participating Judge(s): Diaz, J. Concurs in Result Only: Graves, J. Procedural History: Jury Trial Nature of the Case: CRIMINAL - FELONY |
|
| Trial Court: |
Date of Trial Judgment: 04-29-2004 Appealed from: Tunica County Circuit Court Judge: Al Smith Disposition: Convicted of murder and sentenced to life. District Attorney: Laurence Y. Mellen Case Number: 2001-0087 |
|
| Party Name: | Attorney Name: | |||
| Appellant: | Chris Jones |
ALLAN D. SHACKELFORD |
||
| Appellee: | State of Mississippi | OFFICE OF THE ATTORNEY GENERAL BY: JOHN R. HENRY |
|
|
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 - Expert testimony - M.R.E. 702 - Coroner’s report - M.R.E. 803(8) - Sufficiency of evidence |
| Summary of the Facts: | Chris Jones was convicted of murder and sentenced to life imprisonment. He appeals. |
| Summary of Opinion Analysis: | Issue 1: Expert testimony Jones argues that the court committed reversible error in allowing the State’s expert in crime scene analysis and bloodstain pattern analysis to testify about the stain patterns on Jones’ shirt because the expert could do nothing more than assume that the stains were in fact blood stains. By the time that the expert testified before the jury as to his bloodstain pattern analysis regarding, among other things, Jones’s shirt, the jury had already heard extensive testimony from the serologist regarding the human blood she found on Jones’s shirt. Under M.R.E. 702, there is a two-pronged inquiry which the trial court must perform in making a determination as to whether expert testimony is admissible, in that the trial court must first determine if the proffered testimony is relevant, and if relevant, then is the proffered testimony reliable. Here, the trial court quite appropriately denied Jones’s motion to exclude the expert’s testimony, which was relevant and reliable as to his bloodstain analysis of the stains on Jones’s tee shirt, which had by that time been identified by the serologist before the jury as human blood. The jury had every right to believe or disbelieve any part of, or all of, the testimony of the two experts. The jury was more than adequately instructed by the trial court that if the jury felt that the serologist was mistaken or simply wrong in her opinion regarding the presence of human blood on Jones’s tee shirt, and/or that the other expert was basing his blood pattern analysis on the erroneous belief or unsubstantiated assumptions that the stains were that of human blood, then the jury could disregard this expert testimony in its entirety. Therefore, the court did not commit error in allowing expert testimony concerning blood patterns on Jones’s tee shirt. Issue 2: Coroner’s report Jones argues that the court erred in not allowing him to introduce the coroner’s report into evidence. The coroner who went to the crime scene and subsequently prepared a coroner’s report, died prior to trial. Jones attempted to introduce the coroner’s report into evidence to show to the jury that the coroner had estimated the time of the victim’s death to be 9:30 p.m., which if accepted by the jury, would provide Jones with an alibi since the evidence is undisputed that Jones did not clock out from work until 10:34 p.m. Jones argues that the coroner’s report, at least as to the estimated time of death, is admissible as a public record pursuant to M.R.E. 803(8). The coroner’s report shows that the coroner would have had to rely on hearsay information to complete the report, and it is at least arguable, since he was unavailable to testify due to his unfortunate death prior to trial, that he also relied on this other hearsay information to aid him in estimating the time of death. Additionally, exclusion of the evidence is supported by the comment under M.R.E. 803(8) which gives the judge discretion to exclude such reports if based on hearsay or the opinions of those not involved in the preparation of the report. Issue 3: Sufficiency of evidence Jones argues that the evidence was insufficient. This case was a circumstantial evidence case because Jones did not confess to the crime, nor were there eyewitnesses to the crime. The evidence shows that Jones clocked out from work at 10:34 p.m., presumably to drive to his residence where he and the victim lived. The drive to his residence was no more than a ten minute drive. At 11:29 p.m., Jones made a 911 call requesting law enforcement to come to his residence. The deputy found Jones standing outside his trailer covered in blood and crying. Officers went inside the trailer and found the body of the victim lying partially on the bed and on the floor, face up. There was blood all over the house. There was human blood on Jones’ tee shirt. The blood transfer pattern on Jones’ tee shirt was consistent with the blood transfer pattern on the scarf the victim was wearing at the time her body was discovered. A portion of the front of Jones’ tee shirt contained blood stains consistent with the shirt being in close proximity to a medium velocity or cast off pattern associated with blunt force trauma or a stabbing incident. When this evidence is viewed in the light most favorable to the State, any reasonable, rational and fairminded juror could have found from this evidence that the State had proved, beyond a reasonable doubt and to the exclusion of every other reasonable hypothesis consistent with innocence, each and every element of the crime of deliberate design murder. There was unquestionably conflicting evidence and conflicting theories presented to the jury, and thus, the jury, and only the jury, could determine the facts, as it found the facts to be from the evidence before it, and then apply those facts to the law as properly given to it by the trial court via the written instructions. |
Home | Terms of Use | About the JDP | Feedback | Using JDP | MC Law Library | Mississippi Supreme Court
