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Eddie Minor, III v. State of Mississippi
236 So. 3d 63
| Miss. | 2017
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Background

  • On Dec. 29, 2014, 16‑year‑old Jessie Taylor Jr. was shot in the back in Natchez and later died; he told officers two black males had robbed and shot him.
  • Eight shell casings were recovered (one 9mm separate from seven 9mm casings); a .380 Lorcin pistol was recovered nearby with mixed ammunition; a .38/.9mm bullet was recovered from Taylor.
  • Witness Emanuel “Little Carl” Latham (15) gave statements and testified that Eddie Minor (18) retrieved two guns, pointed a revolver at Taylor, demanded money and Taylor’s gun, and shot as Taylor fled; Latham admitted he also fired until his magazine emptied.
  • Another witness (Keterria) placed Minor with Taylor shortly before the shooting but did not see Minor with a gun; some testimony contained inconsistencies among witnesses.
  • Minor was tried twice: first trial ended in mistrial on a deadlocked jury; second trial resulted in conviction of armed robbery (35 years) and mistrial on murder; State nolle prosequi’d the murder charge.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Sufficiency of the evidence for armed robbery State: Latham’s testimony + corroboration (victim’s statements, Keterria) prove Minor demanded property at gunpoint and used a deadly weapon Minor: testimony contradictory and insufficient; accomplice testimony unreliable Affirmed — evidence sufficient when viewed in light most favorable to prosecution
Weight of the evidence — whether verdict is against overwhelming weight State: jury could credit Latham and other testimony; inconsistencies go to credibility Minor: verdict against overwhelming weight given contradicting accounts and jury deadlock on murder Affirmed — verdict not so contrary to overwhelming weight as to constitute injustice
Accomplice corroboration required State: slight corroboration suffices to support conviction Minor: argues accomplice testimony unreliable and should be discounted Court: accomplice testimony may convict if not unreasonable/improbable and with slight corroboration; corroboration here exists
Relationship between robbery conviction and mistrial on murder Minor: inconsistent to convict for robbery but not murder based on same testimony State: jurors can credit different parts of testimony; Latham’s admitted firing could explain jury’s indecision on who caused death Court: no inconsistency that requires reversal; jury reasonably could acquit/declare mistrial on murder while convicting on robbery

Key Cases Cited

  • Bush v. State, 895 So. 2d 836 (Miss. 2005) (standard for reviewing sufficiency and weight of evidence)
  • Jackson v. Virginia, 443 U.S. 307 (1979) (benchmark: whether any rational trier of fact could find guilt beyond reasonable doubt)
  • Graves v. State, 216 So. 3d 1152 (Miss. 2016) (a single witness’s testimony can support conviction)
  • Johns v. State, 592 So. 2d 86 (Miss. 1991) (accomplice testimony viewed with caution but can suffice)
  • Jones v. State, 203 So. 3d 600 (Miss. 2016) (only slight corroboration of accomplice testimony required)
  • Duncan v. State, 939 So. 2d 772 (Miss. 2006) (inconsistencies in testimony do not mandate rejecting testimony)
  • Clanton v. State, 279 So. 2d 599 (Miss. 1973) (jury resolves witness credibility)
  • Cousar v. State, 855 So. 2d 993 (Miss. 2003) (credibility and weighing conflicting evidence are for the jury)
  • Kirk v. State, 160 So. 3d 685 (Miss. 2015) (reversal for weight-of-evidence only if verdict sanctions unconscionable injustice)
  • Cotton v. State, 144 So. 3d 137 (Miss. 2014) (reasonable jurors must be impossible to find guilt to overturn on weight grounds)
Read the full case

Case Details

Case Name: Eddie Minor, III v. State of Mississippi
Court Name: Mississippi Supreme Court
Date Published: Nov 30, 2017
Citation: 236 So. 3d 63
Docket Number: NO. 2016–KA–01311–SCT
Court Abbreviation: Miss.