Baxter v. State
177 So. 3d 423
| Miss. | 2014Background
- Baxter was convicted of capital murder for Sheriff Gary Welford's death and appeals challenging admissibility and dynamics of the chase.
- Deputy Daffin chased a maroon truck driven by Williams; Baxter was a passenger suspected of involvement with a bench warrant.
- High-speed pursuit ended with Welford’s death; Baxter and Williams were later found hiding in a trailer, Baxter tased and arrested.
- Baxter waived Miranda rights and confessed to driving the pursuit, claiming Williams initially drove and they swapped seats.
- Witnesses disagreed on who drove; several corroborating and conflicting accounts supported Baxter’s claim of Williams’ driving.
- Baxter challenged multiple trial rulings, including suppression, victim-impact testimony, prior-conviction evidence, jury instructions, and parole considerations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there reasonable suspicion/probable cause for the stop? | Baxter | Baxter | Stop supported by reasonable suspicion; Fourth Amendment satisfied. |
| Was Baxter's Miranda waiver voluntary and intelligent? | Baxter | Baxter | Confession admissible; totality of circumstances supports voluntary waiver. |
| Did Williams’s grand-jury testimony involve perjury affecting the indictment? | Baxter | Baxter | No clear perjury established; indictment not dismissed. |
| Was there juror misconduct or prejudicial exposure requiring removal? | Baxter | Baxter | Trial court did not abuse discretion; no reversible juror-prejudice shown. |
| Was Debbie Welford’s testimony improperly a victim-impact statement? | Baxter | Baxter | Not victim-impact testimony; admissible as background, not unduly prejudicial. |
Key Cases Cited
- Eaddy v. State, 63 So.3d 1209 (Miss. 2011) (reasonable suspicion suffices for investigative stops)
- Chim v. State, 972 So.2d 601 (Miss. 2008) (reliability review of voluntary confessions)
- Wells v. State, 698 So.2d 497 (Miss. 1997) (applying totality of circumstances to voluntariness)
- Flowers v. State, 842 So.2d 531 (Miss. 2003) (capital-murder sentencing and related instructions)
- United States v. Basurto, 497 F.2d 781 (9th Cir. 1974) (prosecution duty regarding perjury before grand jury (doubtful vitality, cited))
- United States v. Bracy, 566 F.2d 649 (9th Cir. 1977) (limits of Basurto doctrine on perjury disclosure)
- United States v. Cathey, 591 F.2d 268 (5th Cir. 1979) (clarifies Basurto/Bracy framework)
- Howell v. State, 411 So.2d 772 (Miss. 1982) (jury instruction/ultimate responsibility in criminal verdicts)
- Renfro v. State, 118 So.3d 560 (Miss. 2013) (weight of evidence; jury credibility determinations)
- Beasley v. State, 74 So.3d 357 (Miss.Ct.App. 2010) (voir dire and juror impartiality considerations)