Beasley v. State
136 So. 3d 393
| Miss. | 2014Background
- Beasley was indicted for deliberate-design murder of Janie Wilkinson (over age 65 enhancement) in Amite County, Mississippi.
- Wilkinson’s death occurred May 14–16, 2011; her body found in her locked Liberty home, with extensive head injuries and blood, no forced entry or theft.
- Beasley lived in Wilkinson’s converted apartment; witnesses testified Wilkinson had told Beasley he was upset about moving out.
- DNA and physical evidence linked Beasley to the crime: blood on Beasley-related clothing matched Wilkinson; skin DNA on Beasley’s sweatpants matched Beasley; blood on a napkin and wet bathroom surfaces noted.
- Autopsy determined cause of death as multiple sharp-force trauma; the manner was homicide; injuries could have been caused by a hatchet, ax, or machete; body showed defensive wounds.
- Beasley testified in his defense, claiming he found Wilkinson dead after hearing a disturbance, moved the body, disposed of clothes, and admitted to discarding the dog’s body but denied killing the dog; he did not contact authorities.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Competency hearing compliance | Beasley argues Rule 9.06 hearing required but not properly conducted. | Beasley contends trial court erred by not adequately determining competency. | Court found no reversible error; Rule 9.06 followed and competency supported. |
| Admission of gruesome photographs | Beasley claims photographs were unnecessarily gruesome and prejudicial. | Beasley argues admission violated fairness; contends plain error | Procedural bar applies (no contemporaneous objection), but merits upheld; photographs had probative value supporting scene and causation. |
| Sufficiency of evidence for murder | State proved Beasley killed Wilkinson with deliberate design beyond reasonable doubt. | Beasley asserts insufficient evidence and/or inconsistent with defense. | Evidence legally sufficient to support deliberate-design murder beyond reasonable doubt. |
| Sufficiency/weight - new trial or JNOV | State argues verdict supported by evidence; challenge to weight of evidence. | Beasley seeks JNOV or new trial based on alleged insufficiency/weight. | No JNOV; weight not against overwhelming evidence; no new trial. |
Key Cases Cited
- Drope v. Missouri, 420 U.S. 162 (U.S. 1975) (right not to be tried while incompetent; due process safeguard)
- Emanuel v. State, 412 So.2d 1187 (Miss. 1982) (competency and due process implications in Mississippi cases)
- Dusky v. United States, 362 U.S. 402 (U.S. 1960) (defining standard for competency to stand trial)
- Hearn v. State, 3 So.3d 722 (Miss. 2008) (Rule 9.06 competency hearing compliance)
- Sanders v. State, 9 So.3d 1132 (Miss. 2009) (reversible error for failure to conduct competency hearing under Rule 9.06)
- Jay v. State, 25 So.3d 257 (Miss. 2009) (reversal for lack of competency hearing findings)
- McNeal v. State, 551 So.2d 151 (Miss. 1989) (graphic photographs admissibility framework; weighing prejudicial impact)
- Parker v. State, 119 So.3d 987 (Miss. 2013) (photographs describing scene; probative value supporting testimony)
- McFee v. State, 511 So.2d 130 (Miss. 1987) (photographs admissibility; supplements witness testimony)
- Higgins v. State, 725 So.2d 220 (Miss. 1998) (deadly weapon inference from evidence; deliberate design can be inferred)