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