Derrick Johnson v. State of Mississippi, 198 So. 3d 427

In July 2011 a security guard, Tyrone McKinney, was killed during a robbery at a Jackson Shell station; surveillance showed three men fleeing in a Chevrolet Caprice.
Derrick Johnson was interviewed by JPD Detectives Eric Smith and William Waples on July 29, 2011; Johnson signed a Miranda waiver, confessed on audiotape, signed a written confession, and annotated a robbery photo identifying himself as the shooter.
Johnson was indicted for capital murder (and aggravated assault); he moved to suppress his confession claiming intoxication but the court denied suppression after listening to the tape and hearing testimony that Johnson showed no signs of intoxication.
Before trial the State moved to prohibit cross-examination of Detective Waples about unrelated bribery allegations that led to Waples’ reassignment and eventual resignation; Waples had not been charged or arrested.
The trial court granted the motion in limine; at trial Waples authenticated the confession evidence and testified Johnson was not coerced; Johnson was convicted of capital murder and sentenced to life without parole.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by precluding cross-examination of Detective Waples about alleged bribery	Johnson: cross-examination into bribery allegations would impeach Waples’ credibility and expose possible bias or motive to fabricate	State: allegations were unsubstantiated, unrelated to Waples’ testimony, and would unfairly prejudice the jury	Court: affirmed—preclusion did not abuse discretion; unsubstantiated, unrelated accusations were irrelevant and prejudicial

Ellis v. State, 856 So. 2d 561 (Miss. Ct. App. 2003) (trial court may exclude inquiry into unsubstantiated prior bad acts; Rule 608(b) requires judge to weigh probative value vs. prejudice)
Timmons v. State, 44 So. 3d 1021 (Miss. Ct. App. 2010) (trial court may limit cross-examination to relevant matters)
Reynolds v. State, 784 So. 2d 929 (Miss. 2001) (admissibility and relevancy of evidence within trial court discretion)
Jackson v. State, 594 So. 2d 20 (Miss. 1992) (exclusion of evidence requires showing of prejudice to reverse)
Peterson v. State, 671 So. 2d 647 (Miss. 1996) (relevancy and admissibility determinations largely within trial court discretion)
Brent v. State, 632 So. 2d 936 (Miss. 1994) (trial judge should determine whether specific conduct reflects on witness honesty and weigh Rule 403 considerations)
Miranda v. Arizona, 384 U.S. 436 (1966) (custodial warnings and waiver doctrine)