Clyde Chatman, Jr. v. State of Mississippi
241 So. 3d 649
| Miss. Ct. App. | 2017Background
- Victim Patrick Williams was shot and killed in Jonestown, MS on March 27, 2012; witnesses reported a white car drove by and Williams identified his shooters as being from Friars Point and said "Little Clyde and them."
- Clyde Chatman (aka Little Clyde) was arrested with co-defendants Reginald Cox and John Battle; a white Crown Victoria registered to Chatman’s mother was tied to the scene.
- Forensics: .25-caliber casings from the same gun were recovered; gunshot-residue (GSR) particles were found on Chatman’s palms and in the vehicle; Chatman’s DNA/profile matched material on the car’s rear-door grip and a glove found in the back seat.
- Chatman testified he was driving, denied shooting, and claimed Battle fired the gun; he admitted a romantic interest in the victim’s girlfriend. Chatman’s testimony implicated Cox, prompting severance for Cox.
- A jury convicted Chatman of deliberate-design (first-degree) murder; the trial court, applying Miller v. Alabama, sentenced him to life with parole eligibility. Post-trial motions were denied and Chatman appealed.
Issues
| Issue | Plaintiff's Argument (Chatman) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Confrontation Clause — admission of deputy’s testimony that Battle told police where to search for the gun | Testimony that Battle told police where to look for the gun was testimonial and violated Chatman’s confrontation right | Statement was non-testimonial (investigative context) and, in any event, harmless | No violation; testimony was non-testimonial and, even if error, harmless |
| Sufficiency of evidence for deliberate-design murder | Evidence only shows presence; DNA/GSR and vehicle presence are not dispositive of deliberate design or who fired | Eyewitness IDs, motive, GSR, DNA in car/glove, and circumstances permit inference of deliberate design | Evidence sufficient for conviction when viewed favorably to prosecution |
| Weight of the evidence — whether verdict shocks the conscience | Verdict is against overwhelming weight; alternate explanation (Battle shot) plausible | Verdict supported by cumulative evidence; conflicting testimony resolved by jury | No relief; verdict not against overwhelming weight of evidence |
| Sentencing procedure under Miller v. Alabama (procedural posture noted) | (Raised at sentencing stage) Life sentence with parole eligibility appropriate given juvenile status and Miller considerations | Trial judge considered Miller factors and imposed life with parole eligibility | Sentence affirmed (trial judge applied Miller factors) |
Key Cases Cited
- Crawford v. Washington, 541 U.S. 36 (2004) (Confrontation Clause applies to testimonial statements)
- Davis v. Washington, 547 U.S. 813 (2006) (distinguishes testimonial from nontestimonial statements in interrogation/ongoing-emergency context)
- Miller v. Alabama, 567 U.S. 460 (2012) (juvenile sentencing; mandatory life without parole considerations)
- Chapman v. California, 386 U.S. 18 (1967) (standard for harmless error under the Constitution)
- Bush v. State, 895 So. 2d 836 (Miss. 2005) (standards for sufficiency and weight review in criminal cases)