Jafron Roberts v. State of Mississippi
2016-KA-00847-SCT
| Miss. | Sep 14, 2017Background
- Victim ("Tanya"), age 13, was abducted on Oct. 1, 2013, forced to perform oral sex and engage in intercourse at an abandoned house; she reported details, left underwear in the house, and identified defendant Jafron Roberts.
- Police located Roberts shortly after the incident; he matched victim’s description (skin tone, forearm tattoos, car with loud pipes), and Tanya identified him at the stop; investigators recovered Tanya’s underwear from the house with her DNA.
- Laboratory testing: seminal fluid and sperm cells on Tanya’s pants; vaginal/vulvar swabs showed seminal fluid but only victim’s DNA; a partial Y‑STR profile from the pants did not exclude Roberts or males in his paternal line.
- Roberts was arrested, given Miranda warnings, later gave a statement admitting consensual sex at the house (he denied coercion); he refused to sign a waiver form but continued talking. He was convicted of kidnapping and statutory rape; acquitted of sexual battery.
- On appeal Roberts raised five claims: suppression of his statement (Miranda/voluntariness), in camera review of victim’s prior medical records, State’s loss of potentially exculpatory evidence (surveillance video), exclusion of DNA expert testimony, and pre‑indictment delay. The Mississippi Supreme Court affirmed.
Issues
| Issue | Roberts' Argument | State/Respondent Argument | Held |
|---|---|---|---|
| Motion to suppress statement (Miranda/waiver) | Refused to sign waiver = invoked right to remain silent; earlier requested counsel; any waiver was induced by promises | Officers read Miranda; Roberts never invoked counsel or silence during interview; refusal to sign not per se invocation; statements voluntary | Denial affirmed: waiver and confession voluntary under totality; refusal to sign not an invocation; promise‑inducement claim not preserved and fails on merits |
| In camera review of victim’s medical records (privilege) | Records might show recent sexual activity or injuries that could be exculpatory (possible alternate semen source) | Records privileged; trial court correctly applied rape‑shield principles and Cox/Ritchie framework; relevance limited given victim’s age and statutory‑rape charge | Claim procedurally barred; even if considered, any error harmless beyond reasonable doubt given strong corroborating evidence and confession |
| Loss of potential exculpatory evidence (Webb Hall surveillance) | Police failed to secure surveillance; tapes erased (routine 2‑week retention), prejudicing alibi defense | State did not possess or destroy the tapes; defense did not preserve claim at trial; loss not shown to be in bad faith | Procedurally barred; on merits no due‑process violation—no showing of bad faith or prejudice sufficient to require new trial |
| Admissibility of DNA expert testimony (Y‑STR) | Expert could not state to scientific certainty that Roberts was donor; testimony left jury to speculate | Expert testified Roberts could not be excluded, provided match frequency and confidence level; Y‑STR reliable under Rule 702 | Trial court did not abuse discretion; testimony admissible to show defendant could not be excluded as donor |
| Pre‑indictment delay / Due process | ~1‑year delay before indictment prejudiced defense (alibi witnesses, lost tapes) | Delay primarily due to ongoing DNA testing; defense never moved to dismiss on this basis at trial; no intentional delay to gain tactical advantage | Procedurally barred; on merits no due‑process violation—no prejudice shown and no intentional prosecutorial tactic |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (constitutional warnings and waiver principles)
- Berghuis v. Thompkins, 560 U.S. 370 (voluntary waiver and waiver standards)
- Pennsylvania v. Ritchie, 480 U.S. 39 (in camera review of privileged records for material exculpatory evidence)
- Chapman v. California, 386 U.S. 18 (harmless‑error standard for constitutional errors)
- Delaware v. Van Arsdall, 475 U.S. 673 (harmless‑error analysis for constitutional errors)
- California v. Trombetta, 467 U.S. 479 (State duty to preserve evidence that would play significant role in defense)
- U.S. v. Lovasco, 431 U.S. 783 (pre‑indictment delay due process framework)
- U.S. v. Marion, 404 U.S. 307 (two‑part test for pre‑indictment delay/due process)