Juanteaz McDonald v. State of Mississippi, 226 So. 3d 626

Juanteaz McDonald was indicted in August 2014 on two counts of armed robbery and released on bond.
Pretrial: McDonald attended hearings, initially indicated desire to proceed to trial, and withdrew a prior guilty-plea petition. Trial was set for December 1–2, 2014.
On December 1 the trial was delayed to the next morning; McDonald failed to appear on December 2. Defense counsel reported McDonald’s mother told her McDonald said he was not going to court.
The circuit judge found McDonald had "willfully, voluntarily and deliberately absented himself" and refused a continuance; the trial proceeded in absentia under Miss. Code Ann. § 99-17-9.
A jury convicted McDonald on both counts; he was sentenced to concurrent 50-year terms (10 years suspended) and five years supervised probation. Post-trial motions were denied and McDonald appealed.

Issue	McDonald’s Argument	State’s Argument	Held
Whether the court erred in trying McDonald in absentia	McDonald argued he had shown a desire to participate and his absence did not reflect a willful waiver; proceeding prejudiced his right to be present and to confront/argue witness credibility	Court may proceed when defendant willfully, voluntarily, and deliberately absents; statute and precedent permit trial in absentia	No error — court did not abuse its discretion; McDonald willfully absented himself and waived the right to be present
Whether trial counsel was ineffective	McDonald alleged counsel failed to review evidence with him, subpoena favorable witnesses, challenge juror bias from his absence, or compel evidence	Record does not affirmatively show constitutional ineffectiveness; appellate record is inadequate to resolve claim	Ineffective-assistance claims dismissed without prejudice for collateral review (PCR) because record is insufficient on direct appeal

Haynes v. State, 208 So. 3d 4 (Miss. Ct. App. 2016) (abuse-of-discretion review of trial-in-absentia determinations)
Wales v. State, 73 So. 3d 1113 (Miss. 2011) (defendant who knew trial date and deliberately failed to appear waived right to be present)
Archer v. State, 986 So. 2d 951 (Miss. 2008) (ineffective-assistance claims are generally addressed in post-conviction proceedings)
Wilcher v. State, 863 So. 2d 776 (Miss. 2003) (appellate review limits for ineffective-assistance claims; exceptions where record shows affirmatively)
Read v. State, 430 So. 2d 832 (Miss. 1983) (direct-appeal procedure when record is inadequate for ineffectiveness claims)