Brown v. State, 130 So. 3d 1074

On Nov. 8, 2010 Cheryl McFarland returned to her home, observed a kicked-in door, was attacked by two men who fled in a red car; a .22 pistol from the house was later recovered outside the scene.
Investigators traced a car tag to Sacory Brown’s mother; Mary Brown drove Sacory to the police station for questioning.
On Nov. 11, 2010 Investigator Rutter read the standard four-part Miranda warnings to Brown; Brown signed a written waiver and handwrote an inculpatory statement admitting presence in the car while two others entered the house.
Brown was tried alone for burglary of a dwelling (aggravated assault count mistried); he was convicted and sentenced to 25 years (18 to serve, 7 suspended with 5 years post-release supervision).
Brown appealed, arguing (1) the Miranda warning was deficient for not explicitly stating the right to stop questioning at any time, (2) the 25-year sentence was grossly disproportionate under the Eighth Amendment, and (3) the evidence was legally insufficient and against the overwhelming weight of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Adequacy of Miranda warning / validity of waiver	State: four-fold Miranda warning was given, read aloud, and Brown signed and knowingly waived rights.	Brown: warning was insufficient because it did not explicitly state he could stop questioning at any time; his learning disability undermined voluntariness/knowingness of waiver.	Court: Fourfold Miranda warnings suffice; right to cease questioning is encompassed implicitly; waiver was knowing, intelligent, voluntary.
Eighth Amendment proportionality of 25-yr sentence	State: sentence is within statutory maximum and comparable to prior affirmed sentences for dwelling burglary.	Brown: sentence is grossly disproportionate given age, learning disability, no prior record, lack of physical evidence tying him to entry, and lack of violent act evidence.	Court: No inference of gross disproportionality; sentence within statutory limits; no extended Solem review required.
Legal sufficiency / weight of evidence	State: Brown’s written admission and victim testimony suffice; absence of fingerprints or perfect car ID does not negate guilt.	Brown: lack of physical evidence, victim’s failure to ID in photo lineup, and inconsistencies make conviction unsupported or against the weight of evidence.	Court: Viewing evidence in light most favorable to prosecution, a rational jury could convict; verdict not against overwhelming weight.

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (establishes required custodial warnings and standard for waiver)
Solem v. Helm, 463 U.S. 277 (U.S. 1983) (framework for proportionality review of sentences)
Michigan v. Mosley, 423 U.S. 96 (U.S. 1975) (right to cease questioning must be honored when invoked)
Chim v. State, 972 So.2d 601 (Miss. 2008) (standard for appellate review of Miranda waiver findings)
Coverson v. State, 617 So.2d 642 (Miss. 1993) (totality-of-circumstances test for waiver; consider mental capacity)
Smith v. State, 394 So.2d 1367 (Miss. 1981) (four-fold Miranda warning implicitly includes right to stop questioning)
Hoops v. State, 681 So.2d 521 (Miss. 1996) (discusses proportionality and application of Solem factors)
Mosley v. State, 104 So.3d 839 (Miss. 2012) (upholding lengthy sentences within statutory limits in proportionality context)