Eric Pelletier v. State of Mississippi, 207 So. 3d 1263

Officer stopped Eric Pelletier for an inoperable tag light; Pelletier consented to a vehicle search that revealed 24 Vyvanse tablets (Schedule II) and two weapons (metallic knuckles and a switchblade).
Pelletier, a convicted felon, was arrested and indicted on possession of a Schedule II controlled substance (more than 20 but less than 40 dosage units) and felon-in-possession (metallic knuckles).
Defense failed to provide reciprocal discovery per URCCC 9.04: the defense produced no witness list by the court-ordered deadline and did not disclose “Chuck Cole” until after the State rested.
Trial court excluded Cole (defense’s proposed witness) as a sanction for the late disclosure; defense counsel then presented Pelletier’s testimony that Cole loaned the tool bag containing the knuckles and that the drugs belonged to an unidentified roommate.
Jury convicted Pelletier on both counts; trial court found him a nonviolent habitual offender and imposed concurrent sentences (24 years for drug, 10 years for weapon) and fines.
On appeal Pelletier argued (1) ineffective assistance of counsel and (2) that excluding Cole was an abuse of discretion and violated his Sixth Amendment compulsory-process rights.

Issue	Pelletier's Argument	State's Argument	Held
Whether ineffective-assistance claim can be resolved on direct appeal	Powers’ discovery failures, failure to call “Bryan,” and failure to oppose indictment amendment rendered representation ineffective	Record does not show necessary facts; claim needs further factual development in PCR	Denied on direct appeal; claim preserved for post-conviction relief (not adjudicated now)
Whether trial court abused discretion by excluding defense witness (Cole) for discovery violation	Exclusion violated compulsory-process rights and was prejudicial; defense faulted counsel’s conduct, not client	Late disclosure was intentional/willful, prejudiced State’s ability to investigate/cross-examine; exclusion is an appropriate sanction	No abuse of discretion; exclusion affirmed (trial judge permissibly sanctioned discovery violation); continuance not required

Taylor v. Illinois, 484 U.S. 400 (U.S. 1988) (upholding exclusion of belatedly disclosed defense witness; client bears consequences of counsel’s failures)
Archer v. State, 986 So.2d 951 (Miss. 2008) (ineffective-assistance claims usually reserved for post-conviction relief unless record fully dispositive)
Coleman v. State, 749 So.2d 1003 (Miss. 1999) (trial judge has discretion to exclude evidence for discovery violations; Taylor is not exclusive limit)
Houston v. State, 752 So.2d 1044 (Miss. Ct. App. 1999) (affirming exclusion of late alibi witness where defense ignored discovery rules)
De La Beckwith v. State, 707 So.2d 547 (Miss. 1997) (failure to request continuance does not bar objection to admission of undisclosed evidence; exclusion may still be proper)