120 So. 3d 382
Miss.2013Background
- Natasha Graham was convicted by a Lamar County jury of murder and conspiracy to commit murder, receiving life imprisonment for murder and 20 years for conspiracy, to run consecutively.
- Co-defendant Ethan Dixon testified at Graham’s trial in exchange for a 25-year sentence; his testimony helped the State’s theory of conspiracy.
- Tabitha Hartfield, Tabitha’s husband Ronald, Graham, Dixon, and Ronald’s involvement occurred on May 24, 2008, including a trip to obtain pills and alcohol, followed by confrontations and the attempt to leave Tabitha in Graham’s mobile home.
- Evidence showed Tabitha was restrained, given a pill-water mixture, and later strangled with a dog leash; her body was disposed of in a trailer and later buried in woods.
- Graham’s statements to 911 and to officers indicated she had killed Tabitha and later led investigators to the grave; she claimed Dixon helped hide the body.
- Investigators recovered blue dog leashes and a knife, with later autopsy indicating strangulation as the cause of death and significant decomposition of Tabitha’s remains.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Graham's conspiracy conviction supported by sufficient evidence? | Graham contends there was insufficient evidence of an agreement to murder. | State contends circumstantial evidence shows a shared objective to kill Tabitha. | Sufficient evidence supports conspiracy conviction. |
| Is Graham’s murder conviction against the overwhelming weight of the evidence? | Weight favors Dixon and Ronald; Graham’s involvement is only suggested by her statements. | Graham’s presence, acts aiding the murder, and conspiratorial acts support guilt. | Not against the overwhelming weight; verdict affirmed. |
Key Cases Cited
- Brown v. State, 796 So.2d 223 (Miss. 2001) (circumstantial evidence can support conspiracy and aiding-and-abetting guilt)
- Davis v. State, 485 So.2d 1055 (Miss. 1986) (conspiracy proven by common design from facts and circumstances)
- Riley v. State, 208 Miss. 336, 44 So.2d 455 (Miss. 1950) (conspiracy shown by acts pursuing a common object)
- Spight v. State, 83 So. 84 (Miss. 1919) (earlier authority on conspiracy by conduct)
- Griffin v. State, 480 So.2d 1124 (Miss. 1985) (non-express agreement may support conspiracy)
- Norman v. State, 381 So.2d 1024 (Miss. 1980) (acts of conspirators are the acts of all)