Darius Montrell Wayne a/k/a Darius Wayne a/k/a Darius M. Wayne a/k/a Darius White v. State of Mississippi, 337 So.3d 704

On April 1, 2019, Darius Wayne shot Shavez Aldridge three times; Shavez died at the scene. Wayne and two co-defendants were indicted; Wayne was tried and convicted of first-degree murder and sentenced to life.
Eyewitnesses (Davion, Mickquez, Keith) testified Wayne shot Shavez and that Shavez did not have a gun; firearms and ballistics evidence tied the three projectiles to Wayne’s Taurus 9mm.
Wayne testified at trial and admitted firing three shots but claimed self-defense: that Shavez grabbed Oliver’s SKS from a car, pointed it, and later reached for a gun during a chase, justifying the shots.
Three days after the shooting Wayne gave a recorded statement in which he said Shavez did not point the gun and repeatedly claimed he “blacked out” after the first shot; the State played this recording in rebuttal over defense objections.
Wayne objected that the recording should have been introduced in the State’s case-in-chief, that only impeachment portions should be played (or that he should be allowed surrebuttal), and moved for JNOV/new trial arguing insufficient evidence and that the verdict was against the weight of the evidence.
The Court of Appeals affirmed: trial court did not abuse its discretion admitting the recorded statement in rebuttal (in full), and the evidence was legally sufficient and not against the overwhelming weight to support first-degree murder.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Wayne)	Held
Admissibility of Wayne’s recorded statement as rebuttal	Statement impeached Wayne’s trial testimony about self-defense; rebuttal proper to counteract new details Wayne added at trial	Statement should have been offered in State’s case-in-chief; not proper rebuttal	Admission in rebuttal was within trial court’s discretion because recording materially impeached Wayne’s testimony
Playing entire hour-long recorded statement	Entire recording was impeachment evidence, produced in discovery, not unduly prejudicial	Only portions that impeach should have been played; full recording prejudicial; defense should have been allowed surrebuttal	Issue waived for lack of cited authority; court found entire recording properly impeached trial testimony and its admission was not an abuse of discretion
Sufficiency and weight of the evidence—self-defense vs. first-degree murder	Witnesses, ballistics, lack of victim weapon, and Wayne’s admissions permit reasonable inference he was not acting in necessary self-defense; deliberate design can be inferred from use of deadly weapon and additional shots	Wayne claims first shot was self-defense and subsequent shots did not negate that justification; evidence insufficient and verdict against weight	Verdict affirmed: evidence sufficient to prove elements of first-degree murder beyond reasonable doubt; jury could reject self-defense and verdict was not against overwhelming weight

Powell v. State, 662 So. 2d 1095 (Miss. 1995) (trial court discretion in admitting rebuttal evidence)
Wakefield v. Puckett, 584 So. 2d 1266 (Miss. 1991) (rebuttal evidence principles)
Thompson v. State, 230 So. 3d 1044 (Miss. Ct. App. 2017) (liberal application of rebuttal rule)
McGaughy v. State, 742 So. 2d 1091 (Miss. 1999) (rebuttal evidence doctrine)
Riley v. State, 157 So. 2d 381 (Miss. 1963) (factors when doubt exists over rebuttal reception and surrebuttal opportunity)
Arrington v. State, 267 So. 3d 753 (Miss. 2019) (failure to cite authority forfeits review)
Brooks v. State, 203 So. 3d 1134 (Miss. 2016) (standard of review for JNOV—legal sufficiency)
Body v. State, 318 So. 3d 1104 (Miss. 2021) (accept evidence most favorable to prosecution on sufficiency review)
Johnson v. State, 235 So. 3d 1404 (Miss. 2017) (sufficiency standard articulation)
Jones v. State, 154 So. 3d 872 (Miss. 2014) (weight-of-evidence standard)
Brown v. State, 965 So. 2d 1023 (Miss. 2007) (elements of first-degree murder)
Allen v. State, 299 So. 3d 917 (Miss. Ct. App. 2020) (State’s burden to disprove self-defense)
Harris v. State, 937 So. 2d 474 (Miss. Ct. App. 2006) (continued/unnecessary shooting can negate self-defense)
Holliman v. State, 178 So. 3d 689 (Miss. 2015) (deliberate design may be inferred from use of a deadly weapon)