Aundray Isaac v. State of Mississippi
187 So. 3d 1009
| Miss. | 2016Background
- In 1991 a towel covering the front door of Shannon Jackson’s apartment caught fire; Aundray Isaac was arrested, tried for first-degree arson, convicted in 1992, and sentenced to 12 years.
- This Court reversed Isaac’s conviction in 1994 for insufficient evidence of willfulness and malice, and Isaac was discharged after serving 995 days.
- Isaac filed a timely claim under the Mississippi Wrongful Conviction Act (MWCA) in 2012 seeking statutory compensation; parties stipulated he met six of seven statutory elements.
- The sole contested MWCA issue at the 2014 bench trial was whether Isaac proved by a preponderance that he did not commit the arson (or that his acts did not constitute a felony).
- The trial court found Isaac’s account of an accidental fire not credible, concluded he intentionally set the towel on fire (malice inferred from willfulness), and denied relief.
- On appeal Isaac argued the trial court failed to address malice as a distinct statutory element and erred in finding the fire intentional; the Supreme Court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court erred by not explicitly discussing the malice element of arson | Isaac: Court must find malice separately; no evidence of malice existed | State: Malice can be inferred from willfulness; trial court found intent so malice follows | No error — malice may be inferred from willfulness; trial court’s finding of intent supports malice inference |
| Whether the trial court erred in finding Isaac intentionally set the fire | Isaac: Evidence shows accident; his testimony undisputed and he extinguished the fire quickly | State: Conflicting testimony (including prior inconsistent statements and Jackson’s account) supports intent; claimant bears burden under MWCA | No error — bench factfinding entitled to deference; substantial, credible evidence supports judge’s finding that Isaac failed to prove he did not commit arson |
Key Cases Cited
- Isaac v. State, 645 So. 2d 903 (Miss. 1994) (reversed criminal conviction for insufficient evidence of malice/willfulness)
- Dickerson v. State, 175 So. 3d 8 (Miss. 2015) (malice may be inferred from willfulness in arson cases)
- Scott Addison Constr., Inc. v. Lauderdale Cty. Sch. Sys., 789 So. 2d 771 (Miss. 2001) (de novo review of statutory interpretation; defer to trial factfindings)
- City of Jackson v. Perry, 764 So. 2d 373 (Miss. 2000) (bench findings accorded deference and upheld if supported by substantial credible evidence)
- Reeves Royalty Co., Ltd. v. ANB Pump Truck Serv., 513 So. 2d 595 (Miss. 1987) (undisputed testimony must be accepted if not unbelievable)