Ladell Maggett, Jr. v. State of Mississippi
230 So. 3d 722
| Miss. Ct. App. | 2016Background
- Victim Quenton McKay was found shot six times with his wrists bound; State alleged execution after a drug deal gone bad. Three defendants (Jerry Stewart, Laddell Maggett Jr., Kelvin Taylor) were tried jointly and convicted of capital murder (underlying kidnapping) and possession of a firearm by a convicted felon.
- Prosecution relied primarily on two accomplices-turned-state’s-witnesses, Tresten Chatman and Christopher Anderson, whose accounts generally agreed that Stewart arranged a cocaine purchase that was mostly baking soda, followed by McKay’s abduction and execution; their statements contained inconsistencies and prior denials.
- Defendants presented alternative explanations: Stewart claimed a limited role (driver) and blamed others; Stewart and Maggett offered alibi witnesses; Taylor raised similar challenges and factual attacks on evidence handling.
- Trial court denied motions to impeach one witness with remote convictions, to sever trials, and excluded certain cell‑phone records for lack of authentication; accomplice testimony was the subject of a cautionary jury instruction.
- Defendants raised multiple procedural and substantive claims on appeal (e.g., indictment sufficiency, admissibility of statements and records, prosecutorial misconduct, weight/sufficiency of evidence, ineffective assistance), but the Court of Appeals affirmed the convictions and sentences.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Impeachment with >10‑yr convictions (Rule 609) | Maggett: trial court erred denying use of Anderson’s old convictions to impeach | Court: Rule 609(b) (over 10 yrs) requires balancing; trial court applied proper standard | Denial not an abuse of discretion; admissibility reviewed under Rule 609(b) and affirmed |
| Severance of trials | Stewart/Maggett: misjoinder and prejudice required separate trials | State: joint trial proper; evidence of drug deal admissible against all as part of the single transaction | Denial of severance upheld; no showing of prejudice and joint trial serves justice |
| Indictment sufficiency for capital murder (identity of kidnapping victim) | Defendants: indictment defective for not explicitly naming McKay as victim of underlying kidnapping | State: Batiste controls—underlying felony must be identified by statute, not victim identity (except burglary) | Indictments adequate under Batiste; Rowland limited/superseded; issue without merit |
| Admissibility of accomplice statements (party admission/co‑conspirator) | Maggett/Stewart: pretrial recorded statements by Anderson/Chatman were party admissions or co‑conspirator statements | State: witnesses are not party opponents; no hearsay exception; statements used for impeachment | Court: statements not admissible as party/co‑conspirator admissions but defendants could use them for impeachment; ruling upheld |
| Sufficiency / corroboration of accomplice testimony | Defendants: convictions rest on uncorroborated, inconsistent accomplice testimony | State: accomplice testimony corroborated by slight details; jury credited witnesses | Court: corroboration of central facts lacking but cautionary instruction given; credibility for jury; evidence sufficient for conviction |
| Weight of the evidence (Taylor) | Taylor: verdict against overwhelming weight; accomplice story unreasonable | State: jury entitled to resolve inconsistencies; reasonable inferences support verdict | Denial of new trial affirmed; not an exceptional case warranting reversal |
| Authentication of cell‑phone records (Rule 902(11)) | Maggett/Stewart: records self‑authenticating; admissible | State: proponent failed to give required notice under Rule 902(11)(C); authentication separate from hearsay exceptions | Exclusion proper for lack of required notice/authentication |
| Prosecutorial misconduct (various) | Defendants: improper questions/remarks, suppression of evidence, Napue claim | State: many objections waived; alleged errors harmless; no proof of knowing use of false evidence | Most claims procedurally barred or harmless; no reversible prosecutorial misconduct |
| Ineffective assistance of counsel / judicial misconduct | Defendants (pro se): counsel failed to investigate/object; judge ignored complaints | State: record insufficient for direct‑appeal ineffective‑assistance review | Claims denied without prejudice to post‑conviction relief; judicial‑misconduct claim unsupported |
Key Cases Cited
- Young v. State, 731 So. 2d 1145 (Miss. 1999) (discusses Rule 609 impeachment issues in context of parties and non‑parties)
- Gray v. State, 728 So. 2d 36 (Miss. 1998) (limits on pleading elements of underlying felony in capital murder indictments)
- Batiste v. State, 121 So. 3d 808 (Miss. 2013) (holding that underlying felony must be identified by statute in capital‑murder indictment; victim identity not required except for burglary)
- Bush v. State, 895 So. 2d 836 (Miss. 2005) (standard for reviewing sufficiency of evidence/Jackson v. Virginia standard)
- Jackson v. Virginia, 443 U.S. 307 (1979) (establishes standard for sufficiency review: evidence viewed in light most favorable to prosecution)
- Cowart v. State, 178 So. 3d 651 (Miss. 2015) (rules concerning convictions based on accomplice testimony and when cautionary instruction is required)
- Osborne v. State, 54 So. 3d 841 (Miss. 2011) (corroboration requirement: only slight corroboration needed, but must connect defendant to crime)
- Goodson v. State, 566 So. 2d 1142 (Miss. 1990) (state witnesses not party‑opponents for Rule 801(d)(2) purposes)
- Franklin v. State, 136 So. 3d 1021 (Miss. 2014) (prosecutorial argument standard for reversible error)