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Chaddy Brooks v. State of Mississippi
203 So. 3d 1134
| Miss. | 2016
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Background

  • On Nov. 22, 2013, Chaddy Brooks discovered texts on her boyfriend Danielle Gore’s phone, a confrontation ensued, and Brooks stabbed Gore in the neck with a kitchen knife.
  • Brooks called 911 and admitted she grabbed a knife and that it “swung” into Gore’s neck while he tried to take it from her.
  • At booking Brooks gave varying accounts: she described being pushed and grabbed, said she retrieved the knife to keep Gore from hurting her, and later testified she got the knife to force him to leave.
  • Brooks admitted she was the initial aggressor, Gore had no weapon, and she had no visible injuries; police found a large kitchen knife near Gore’s body.
  • A jury convicted Brooks of second-degree murder; she was sentenced to 40 years and appealed, arguing (1) insufficient evidence for second-degree murder and (2) ineffective assistance because counsel failed to renew a directed-verdict motion at trial.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Sufficiency of evidence for 2nd-degree murder (depraved-heart) Brooks: evidence insufficient; she acted defensively, turned her back to avoid stabbing, and Gore approached to take knife. State: introducing a deadly weapon into an unthreatened dispute and being initial aggressor supports depraved-heart murder. Affirmed: evidence, viewed in State’s favor, supported conviction for second-degree murder.
Ineffective assistance for failing to renew directed verdict Brooks: counsel’s failure to renew denied a preserved challenge to sufficiency and was constitutionally deficient. State: counsel moved for directed verdict after State’s case and filed post-trial JNOV/new-trial motions, giving court opportunity to review sufficiency. Affirmed: no ineffective assistance; post-trial motions cured any procedural lapse per Simon.

Key Cases Cited

  • Weathersby v. State, 165 So.2d 207 (Miss. 1964) (defendant’s account must be accepted if sole eyewitness and not materially contradicted)
  • Fairley v. State, 871 So.2d 1282 (Miss. 2004) (Weathersby inapplicable when defendant presents conflicting statements)
  • Bush v. State, 895 So.2d 836 (Miss. 2005) (standard for reviewing sufficiency of evidence: view evidence in light most favorable to prosecution)
  • Kirk v. State, 160 So.3d 685 (Miss. 2015) (denial of JNOV reviewed de novo)
  • Warren v. State, 187 So.3d 616 (Miss. 2016) (quoting sufficiency review standard)
  • Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two‑part test for ineffective assistance: deficient performance and prejudice)
  • Holland v. State, 656 So.2d 1192 (Miss. 1995) (failure to move or preserve sufficiency challenge can constitute ineffective assistance)
  • Simon v. State, 857 So.2d 668 (Miss. 2003) (post‑trial motions challenging sufficiency can cure failure to renew directed verdict)
  • Dartez v. State, 177 So.3d 420 (Miss. 2015) (discussing the presumption of reasonable professional assistance)
Read the full case

Case Details

Case Name: Chaddy Brooks v. State of Mississippi
Court Name: Mississippi Supreme Court
Date Published: Nov 17, 2016
Citation: 203 So. 3d 1134
Docket Number: NO. 2015-KA-00933-SCT
Court Abbreviation: Miss.