151 So. 3d 1025
Miss. Ct. App.2014Background
- Bryant was convicted of murder and sentenced to life in the Mississippi DOC.
- At a May 1, 2009 party at the Bee Hive Club, Bryant allegedly gave his gun to the owner to hold.
- A sequence of fights occurred outside and inside the club, including a shooting of Lamarco Tate.
- Bryant testified he did not have a gun and could not identify the shooter; witnesses supported competing theories.
- Bryant challenged juror misconduct and the weight/sufficiency of the evidence; the trial court denied relief.
- The appellate court affirmed, finding adequate inquiry into juror misconduct and sufficient evidence to support the verdict.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Jury-tampering hearing adequacy | Bryant argues outside influence was shown and the hearing was inadequate | State contends inquiry was fair and adequate under Rule 606(b) and Roach | No reversible error; inquiry deemed fair and adequate |
| Sufficiency of the evidence | Bryant claims insufficient evidence supports murder conviction | State asserts eyewitness and expert testimony establish guilt | Sufficient evidence supports the murder verdict |
Key Cases Cited
- Rutland v. State, 60 So.3d 137 (Miss. 2011) (juror misconduct inquiry protections under Rule 606(b))
- Roach v. State, 116 So.3d 126 (Miss. 2013) (process for juror misconduct inquiries and threshold showing required)
- Gladney v. Clarksdale Beverage Co., 625 So.2d 407 (Miss. 1993) (presumption of jury impartiality and threshold showing to raise misconduct)
- Daniels v. State, 107 So.3d 961 (Miss. 2013) (standard for reviewing JNOV on sufficiency of evidence)
- Mitchell v. State, 803 So.2d 479 (Miss.Ct.App.2001) (weight of evidence; credibility of witnesses is jury's concern)
- Dampeer v. State, 989 So.2d 462 (Miss.Ct.App.2008) (abuse-of-discretion standard for new-trial motions)