Watson v. State
| Docket Number: | 2001-KA-01829-COA | |
| Court of Appeals: |
Opinion Link Opinion Date: 06-17-2003 Opinion Author: Irving, J. Holding: Affirmed |
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| Additional Case Information: |
Topic: Forcible rape - Right to speedy trial - Sufficiency of evidence Procedural History: Jury Trial Nature of the Case: CRIMINAL - FELONY |
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| Trial Court: |
Date of Trial Judgment: 01-13-2000 Appealed from: Harrison County Circuit Court Judge: Kosta N. Vlahos Disposition: RAPE: SENTENCED TO SERVE TWELVE YEARS IN THE CUSTODY OF THE MDOC. District Attorney: Cono A. Caranna, II Case Number: 98-00227 |
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| Party Name: | Attorney Name: | |||
| Appellant: | Clarence Troy Watson a/k/a Glenn Lavel Bension |
TOM SUMRALL |
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| Appellee: | State of Mississippi | OFFICE OF THE ATTORNEY GENERAL BY: SCOTT STUART |
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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. |
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| Topic: | Forcible rape - Right to speedy trial - Sufficiency of evidence |
| Summary of the Facts: | Clarence Watson was found guilty of forcible rape and was sentenced to twelve years. He appeals. |
| Summary of Opinion Analysis: | Issue 1: Speedy trial Watson argues that he was denied his right to a speedy trial. Factors to consider in determining if a defendant’s constitutional right has been denied include length of delay, reason for delay, defendant’s assertion of his right, and resulting prejudice. The delay between Watson’s arrest and trial was 817 days which is presumptively prejudicial. A number of continuances in this case were ordered at the behest of both the prosecution and the defense, as well as the court acting sua sponte. Only 160 days for continuances are clearly chargeable to Watson. Of the remaining 657 days, the trial court found good cause existed for delays totaling 366 days, leaving 291 days for which no explanation has been provided. Therefore, this factor weighs in Watson’s favor. Watson filed three separate pro se demands for a speedy trial which weighs in his favor. Watson has not demonstrated any actual prejudice that he has experienced. Therefore, this factor cannot weigh in his favor. Given all these factors, Watson was not denied his constitutional right to a speedy trial. Issue 2: Sufficiency of evidence Watson argues that the evidence is insufficient, because the victim’s testimony is ambiguous in regards to sexual penetration and the use of force or threats and there was insufficient physical evidence that Moore was forcibly raped or that she acted out of fear. The unsupported word of the victim of a sex crime is sufficient to support a guilty verdict where that testimony is not discredited or contradicted by other credible evidence, especially if the conduct of the victim is consistent with the conduct of one who has been victimized by a sex crime. The victim’s mental state following the rape was consistent with the conduct of someone who had been raped. She told her boss about the rape, and he took her to the hospital for a medical analysis and called the police. This activity is indicative of a rape having occurred. It is the jury's duty to weigh conflicting testimony and witness credibility, and the conflict between the testimony of Watson and Moore was properly resolved by the jury. |
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