Goforth v. State
2011 Miss. LEXIS 449
| Miss. | 2011Background
- Amanda Goforth, a former high-school biology teacher, was indicted on five counts of sexual battery involving a former student (Doe).
- At trial, the State presented Doe's testimony and Rigdon’s prior written statement, which Doe had said was fabricated; Rigdon could not recall events due to memory loss after an accident.
- Rigdon’s prior testimonial statement was admitted and read to the jury despite Goforth’s Confrontation Clause objection, because the judge concluded Rigdon was available to testify and that Rule 803(5) applied.
- Doe testified that Goforth engaged in sexual activity with her on multiple occasions, with others present on at least one occasion; Moore and Rigdon corroborated portions of Doe’s account.
- Goforth did not testify; the defense presented witnesses about a harassment incident and a psychologist’s testimony about Goforth’s depression/PTSD.
- The jury found Goforth guilty on two counts and not guilty on three; the trial court sentenced her to a combined 30-year term.
- The Mississippi Supreme Court reversed and rendered, holding the Confrontation Clause was violated and that double jeopardy precluded retrial on the same charges or time period.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Confrontation Clause violation | Goforth contends Rigdon’s memory loss made him unavailable for cross-examination. | State argues Rigdon appeared and could be cross-examined; admissibility under Rule 803(5). | Violation; reversal and render. |
| Double jeopardy precludes retrial | Indictment’s identical, carbon-copy counts prevent distinguishing convictions/acquittals for future prosecution. | No double jeopardy issue if retrial differentiates charges; but the record does not. | Retrial barred; double jeopardy precludes prosecution on same charges/timeframe. |
Key Cases Cited
- Davis v. Washington, 547 U.S. 813 (U.S. 2006) (testimonial statements and confrontation principles)
- Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (Confrontation Clause limits on testimonial statements)
- Owens, 484 U.S. 554 (U.S. 1988) (memory loss and confrontation rights)
- Smith v. State, 986 So.2d 290 (Miss. 2008) (confrontation analysis in Mississippi context)
- Tapper v. State, 47 So.3d 95 (Miss. 2010) (multi-count indictments and notice)
- Valentine v. Konteh, 395 F.3d 626 (6th Cir. 2005) (multiple identical counts and double jeopardy risk)
- People v. Simmons, 123 Cal.App.3d 677 (Cal. Ct. App. 1981) (confrontation and cross-examination of a declarant with amnesia)