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