Edwards v. State
| Docket Number: | 2002-KA-00151-COA Linked Case(s): 2002-KA-00151-COA ; 2002-CT-00151-SCT |
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| Court of Appeals: |
Opinion Link Opinion Date: 06-17-2003 Opinion Author: Irving, J. Holding: Affirmed |
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| Additional Case Information: |
Topic: Depraved heart murder - Hearsay - M.R.E. 803(3) - Objectionable remark - Mistrial - Suppression of statement - Consent to search - DNA evidence - Peremptory instruction - Lesser-included offense instruction Judge(s) Concurring: McMillin, C.J., King and Southwick, P.JJ., Bridges, Thomas, Lee, Myers, Chandler and Griffis, JJ. Procedural History: Jury Trial Nature of the Case: CRIMINAL - FELONY |
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| Trial Court: |
Date of Trial Judgment: 11-20-2001 Appealed from: Tallahatchie County Circuit Court Judge: Andrew C. Baker Disposition: DEPRAVED HEART MURDER: SENTENCED TO SERVE A TERM OF LIFE IMPRISONMENT PURSUANT TO MISSISSIPPI CODE ANNOTATED SECTION 99-19-81, AS AMENDED, AS A HABITUAL CRIMINAL IN THE CUSTODY OF THE MISSISSIPPI DEPARTMENT OF CORRECTIONS. District Attorney: John W. Champion Case Number: CR2001-7-B-T2 |
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| Party Name: | Attorney Name: | |||
| Appellant: | Nathaniel L. Edwards, Jr. |
TOMMY WAYNE DEFER
DAVID L. WALKER |
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| Appellee: | State of Mississippi | OFFICE OF THE ATTORNEY GENERAL: BY: JOHN R. HENRY |
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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: | Depraved heart murder - Hearsay - M.R.E. 803(3) - Objectionable remark - Mistrial - Suppression of statement - Consent to search - DNA evidence - Peremptory instruction - Lesser-included offense instruction |
| Summary of the Facts: | Nathaniel Edwards was convicted of depraved heart murder and was sentenced to life imprisonment. He appeals. |
| Summary of Opinion Analysis: | Issue 1: Hearsay Edwards argues that the court erred when it denied his motion in limine which sought to prevent the State from admitting or eliciting certain hearsay testimony during Edwards's trial. The hearsay concerns a statement allegedly made by the victim to a deputy. A hearsay statement may be admitted under M.R.E. 803(3) to prove a declarant's existing mental, emotional or physical condition but cannot be admitted unless it relates to the execution, revocation, identification, or terms of the declarant’s will. Because the statement in question in this case is a statement of belief to prove a fact believed by the victim but does not relate to the execution, revocation, identification, or terms of the victim's will, the court erred in admitting it. However, admission of the statement was harmless error since the properly admitted evidence is more than sufficient to support the jury's verdict. Issue 2: Mistrial Edwards argues that the court erred when it failed to grant him a mistrial after the assistant district attorney elicited testimony from a witness concerning Edwards's alleged drug use. Where serious and irreparable damage has not resulted from an objectionable remark, the judge should admonish the jury to disregard the impropriety. The jury is presumed to have followed the directions of the judge. Any harm done in this case was cured by the court’s instruction to the jury to disregard the question. Issue 3: Suppression of statement Edwards argues that the court erred when it denied his motion to suppress his statement, because he did not freely and voluntarily confess to law enforcement officers since he was in need of medical attention and was intoxicated at the time. To be admissible, a confession must have been given voluntarily and not given because of promises, threats or inducements. The prosecution meets its burden of proving that the confession was voluntary 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. There exists no corroborative evidence that Edwards’s confessions were the result of bargained-for medical treatment or that he was inebriated to the extent that he was unaware of what he was doing when he gave his confessions. Edwards also argues that the court erred when it denied his motion to suppress evidence resulting from the seizure of his clothing. In determining the voluntariness of a defendant's consent to search, courts must assess whether the defendant was immature and impressionable or experienced and well-educated and whether the defendant was in an excited emotional state, mentally incompetent, or under the influence of drugs or alcohol at the time of the purported consent. Edwards agreed to relinquish his clothing, and his ability to consent to the search and seizure was not negated by intoxication. Issue 4: DNA evidence Edwards argues that the court erred when it overruled his objection to the testimony of a witness regarding statistical data of the DNA evidence. Where the court finds that evidence of a DNA match is admissible as relevant, the court should also allow scientific statistical evidence which shows the frequency with which the match might occur in a given population. Here, the witness was competent to testify how the statistical results were arrived. In addition, Edwards did confront the witness through cross-examination and had a sufficient opportunity to challenge both the DNA comparison process and his knowledge of the statistical compilations. Issue 5: Jury instructions Edwards argues that the court erred when it denied both his request for a peremptory instruction and his request for an instruction on manslaughter. With regard to the peremptory instruction, Edwards has failed to present any argument in support of his claim. With regard to his manslaughter instruction, a lesser-included-offense instruction should be given if there is an evidentiary basis in the record that would permit a rational jury to find the defendant guilty of the lesser-included offense and to acquit him of the greater offense. There is no evidence in the record which suggests Edwards was acting in the heat of passion. Jury instructions are to be granted only where evidence has been presented which supports the instruction. |
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