Edwina Robbins v. State of Mississippi
235 So. 3d 205
| Miss. Ct. App. | 2017Background
- Robbins, Hinton, and Moody were indicted for armed robbery and conspiracy for the November 21, 2014 theft of Lisa Barnes’s car keys and ~$40 while Hinton threatened Barnes with a knife; Hinton pled guilty and testified for the State.
- Barnes went to Robbins’s home to discuss a drug debt; evidence and testimony indicated Robbins sold drugs and Barnes owed her for crack cocaine.
- Witness Jaylon Bolton (Robbins’s son’s boyfriend) and Hinton testified that Hinton assaulted Barnes, threatened her with a knife, took $40 and the car keys; Robbins returned to the room during the incident.
- Thado McSwain testified (over defense objection) that Hinton later threatened/assaulted him at Robbins’s home while allegedly collecting money owed to Robbins; Robbins moved to exclude this and drug-dealer evidence as improper 404(b)/403 evidence.
- The trial court admitted the disputed evidence, Robbins was convicted of simple robbery (lesser-included of armed robbery) and sentenced to 15 years; her post-trial motion was denied and she appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admission of evidence of Robbins’s drug dealing and McSwain incident (other-bad-acts) | Robbins: Evidence was inadmissible under Rule 404(b) and more prejudicial than probative under Rule 403; it invited propensity inference | State: Evidence was inextricably intertwined, admissible for motive/intent/plan; trial court implicitly balanced probative v. prejudicial; any error harmless due to overwhelming evidence | Court: No abuse of discretion; admission proper or any error harmless; issue without merit |
| Sufficiency of evidence for robbery conviction | Robbins: State failed to prove essential elements beyond a reasonable doubt | State: Testimony (Barnes, Hinton, Bolton), texts, and knife evidence supported conviction for (at least) simple robbery | Court: Viewing evidence in light most favorable to prosecution, sufficient proof for simple robbery; conviction affirmed |
| Weight of the evidence (new-trial standard) | Robbins: Verdict against overwhelming weight; inconsistent/conflicting testimony undermines verdict | State: Evidence preponderant for guilt; inconsistencies do not demand new trial absent unconscionable injustice | Court: No unconscionable injustice; discretionary new-trial relief not warranted |
| Use of 404(b) to show modus operandi/plan | Robbins: Use of other incident impermissibly suggested propensity | State: Permissible to show plan/collection method linking acts | Court: Trial court acted within discretion to admit as probative of plan/motive; no reversible error |
Key Cases Cited
- Green v. State, 89 So. 3d 543 (Miss. 2012) (standard for admissibility of other-acts evidence and trial judge discretion)
- Hoffman v. State, 189 So. 3d 715 (Miss. Ct. App. 2016) (standard for viewing evidence in the light most favorable to the prosecution)
- Bush v. State, 895 So. 2d 836 (Miss. 2005) (standard for sufficiency and new-trial relief when verdict is against the overwhelming weight of the evidence)
- Fulcher v. State, 805 So. 2d 556 (Miss. Ct. App. 2001) (definition and use of lesser-included offense concept)