Chancellor v. State, 2015 Miss. LEXIS 173

Background

Jamil Chancellor (nearly 18) was convicted by a jury of armed robbery and armed carjacking after robbing Marcell Cox at gunpoint; he fled after being shot and was arrested with a gun, phone, and cash.
Chancellor gave two statements implicating that Latanya Buckner (aka World) recruited him to rob her boss; he claimed fear of Buckner and her gang affiliations but never stated he was physically forced at the time of the crimes.
The State moved in limine to exclude evidence of Chancellor’s education; the trial court initially reserved then ultimately allowed Chancellor to testify about his limited schooling (third grade) during his testimony.
Defense sought to cross-examine a detective about Buckner’s alleged arrest history (1997 and other arrests) to support a duress defense; the trial court excluded that line of questioning as remote, not shown to involve convictions, and more prejudicial/confusing than probative under Rules 401, 402, 403 and (erroneously, per concurrence) 609.
Chancellor testified extensively about Buckner’s dangerous reputation, gang affiliation, threats, kidnapping/assault to recover her car, being guarded by her people, and that he feared for his life; he did not have personal knowledge of Buckner’s prior arrests.
The court affirmed convictions and sentences (25 years with 10 suspended on each count, concurrent, plus a 5-year firearm enhancement), holding that any exclusion of evidence did not deprive Chancellor of presenting his duress defense and was harmless or within the court’s discretion.

Issues

Issue	Plaintiff's Argument (Chancellor)	Defendant's Argument (State)	Held
Admissibility of defendant’s education	Education relevant to voluntariness of statements and duress; should be admitted	Irrelevant and potentially sympathy-seeking; but no objection if defendant testifies to basic background	Court allowed defendant to testify to grade level; exclusion motion did not prejudice him — no error
Cross-examination re: Buckner’s arrest history	Detective should be asked about Buckner’s arrests to show she was dangerous and to support duress	Arrests remote, no convictions shown, irrelevant, and more prejudicial/misleading than probative	Trial court excluded arrest-history questioning under relevance/403; appellate court affirmed as within discretion or harmless because duress evidence otherwise admitted
Applicability of Rule 609 to arrests (concurrence point)	Rule 609 was wrongly invoked to bar questioning about arrests	Rule 609 governs convictions for impeachment; arrests are not convictions and 10-year rule not applicable	Concurrence: trial court erred to rely on Rule 609 but exclusion was still proper under Rule 403 because defendant lacked personal knowledge of arrests
Whether exclusion denied right to present defense (Ervin reliance)	Exclusion prevented full presentation of duress defense, analogous to Ervin where limiting cross-examination affected fair trial	Ervin distinguishable; here excluded evidence would only paint Buckner as a "bad person" without connection to duress; defendant otherwise presented extensive duress evidence	Court: Ervin is distinguishable; no reversible error and any error was harmless

Key Cases Cited

Whitaker v. State, 146 So.3d 333 (Miss. 2014) (standard: abuse-of-discretion for evidentiary rulings)
Smith v. State, 986 So.2d 290 (Miss. 2008) (abuse-of-discretion standard for evidentiary rulings)
Jennings v. State, 127 So.3d 185 (Miss. 2013) (education relevant to voluntariness of custodial confession)
Ervin v. State, 136 So.3d 1053 (Miss. 2014) (exclusion of cross-examination can impair presentation of defense and require reversal when it prevents relevant impeachment)
Ruffin v. State, 992 So.2d 1165 (Miss. 2008) (definition and scope of duress defense)
Clark v. State, 40 So.3d 531 (Miss. 2010) (admission of relevant evidence and defendant’s right to present a defense)
Newell v. State, 49 So.3d 66 (Miss. 2010) (right to present defense and limits on excluding probative evidence)