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Jabroski Lloyd v. State of Mississippi
228 So. 3d 953
| Miss. Ct. App. | 2017
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Background

  • Defendant Jabroski Lloyd was indicted for kidnapping and aggravated assault after an incident on March 9–10, 2013 in which a blue car driven by Kendrick Cage (with passengers Keith Thomas and Patrick Adams) struck a red car driven by off‑duty deputy Touman Reed; Lloyd jumped into the blue car with a gun and ordered Cage to drive away.
  • As the blue car drove, Thomas and Adams jumped out; Lloyd allegedly fired at Reed’s red car from the blue car and threatened Cage to keep driving; Cage later fled the vehicle and reported the incident to law enforcement.
  • Investigator Williams arrested Lloyd the same night, collected gunshot‑residue (GSR) samples from Lloyd; lab analysis found particles "indicative of gunshot residue" on Lloyd’s left hand.
  • At trial, Cage identified Lloyd as the shooter; defense attempted to impeach Cage with a purported recantation letter Cage had signed while incarcerated, claiming he falsely accused Lloyd to avoid charges for ramming Reed’s car.
  • Cage testified he signed the letter without reading it after meeting defense counsel in jail and denied authoring or mailing it; the letter was used only for impeachment and was not admitted as substantive evidence.
  • Jury convicted Lloyd of aggravated assault; kidnapping charge resulted in mistrial. Lloyd moved for a new trial arguing the verdict was against the overwhelming weight of the evidence; the trial court denied the motion and this appeal followed.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the verdict is against the overwhelming weight of the evidence State: Cage’s eyewitness ID, GSR results, and Reed’s testimony support the conviction Lloyd: Cage is unreliable; his signed jail letter recants his identification and shows false accusation Court affirmed: verdict not against overwhelming weight; impeachment letter not substantive evidence and jury credibility findings control

Key Cases Cited

  • Bush v. State, 895 So. 2d 836 (Miss. 2005) (standard for overturning verdict as against the overwhelming weight of the evidence)
  • Moffett v. State, 456 So. 2d 714 (Miss. 1984) (prior inconsistent out‑of‑court statements by a nonparty witness are not substantive evidence)
  • Turner v. State, 771 So. 2d 973 (Miss. Ct. App. 2000) (recantation alone does not automatically require a new trial)
  • Jones v. State, 95 So. 3d 641 (Miss. 2012) (appellate court will not reassess witness credibility where evidence supports the verdict)
  • Massey v. State, 992 So. 2d 1161 (Miss. 2008) (deference to jury credibility determinations)
  • Brown v. State, 764 So. 2d 463 (Miss. Ct. App. 2000) (jury as factfinder tasked with assessing witness demeanor and credibility)
Read the full case

Case Details

Case Name: Jabroski Lloyd v. State of Mississippi
Court Name: Court of Appeals of Mississippi
Date Published: Mar 7, 2017
Citation: 228 So. 3d 953
Docket Number: NO. 2015-KA-00833-COA
Court Abbreviation: Miss. Ct. App.