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