Kevin Ladexter Carter v. State of Mississippi, 288 So.3d 397

Kevin Ladexter Carter and Angela Collier had a long, on-again/off-again and increasingly violent relationship; Collier was killed by a gunshot on February 12, 2017.
Co-resident Delisa Aills and Collier’s uncle Johnny Shumaker witnessed the post-shooting scene and described prior episodes of domestic violence by Carter against Collier.
Prior incidents included threats with a cocked handgun, physical beatings, attempts to burn Collier’s car, repeated forced-entry attempts, and changed locks; one prior incident was excluded because Shumaker did not personally witness it.
Carter admitted a physical struggle in the bathroom and claimed the rifle discharged accidentally; he denied many prior-incident details but conceded a violent past and that Collier had pressed charges previously.
A jury convicted Carter of second-degree murder, aggravated assault, and felon-in-possession of a firearm; court sentenced consecutive terms and denied a new-trial motion.
On appeal Carter argued the trial court erred by admitting prior-bad-act testimony without conducting an on-the-record Rule 403 balancing; the Court of Appeals affirmed, finding no abuse of discretion.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Carter)	Held
Admissibility of prior domestic violence evidence under M.R.E. 404(b)	Testimony was admissible to show motive, intent, absence of accident, and to provide a coherent narrative	Prior-act testimony was unduly prejudicial and should have been excluded	Evidence admissible under Rule 404(b)(2); trial court did not abuse discretion admitting it
Whether trial court’s failure to state an on-the-record Rule 403 balancing requires reversal	The court considered authorities and counsels’ arguments; an express recitation of Rule 403 is not required	Failure to perform and state an on-the-record Rule 403 balancing violated Carter’s due process and required reversal	No reversible error; on-the-record “magic words” not required absent patently prejudicial evidence; court’s denial affirmed

Jones v. State, 920 So.2d 465 (Miss. 2006) (on-the-record Rule 403 recital not required; reversal only if evidence patently prejudicial)
Pitchford v. State, 45 So.3d 216 (Miss. 2010) (Rule 404(b) exceptions are subject to a Rule 403 probative-vs.-prejudice balancing)
Marbra v. State, 904 So.2d 1169 (Miss. Ct. App. 2004) (pattern of domestic violence admissible to show the act was not accidental)
Moss v. State, 727 So.2d 720 (Miss. Ct. App. 1998) (prior threats and abuse admissible to show escalating violence culminating in murder)
Brink v. State, 888 So.2d 437 (Miss. Ct. App. 2004) (failure to articulate Rule 403 balancing on the record not reversible where court considered arguments)
Horton v. State, 253 So.3d 334 (Miss. Ct. App. 2018) (same principle: absence of explicit Rule 403 “magic words” does not alone require reversal)