Larrell Donta Abram a/k/a Larrell Abram v. State of Mississippi, 309 So.3d 579

On Oct. 7, 2016, Columbia police stopped a silver vehicle after a domestic-disturbance call; Officer Barnes found a .38 revolver on the rear floorboard and arrested Larrell Abram (a convicted felon) and passenger Sasha Ishman.
Ishman told officers Abram had the gun; later at trial she testified in exchange for dismissal of her charge that Abram hid the gun under the seat after a physical altercation.
Abram was indicted and tried for possession of a firearm by a felon; a jury convicted him on Jan. 9, 2019.
The circuit court sentenced Abram as a habitual offender to ten years (five to serve) plus five years post-release supervision. Abram’s post-trial motions were denied and he appealed.
On appeal Abram asserted: (1) the judge improperly commented on evidence; (2) the court abused its discretion admitting evidence of prior bad acts; (3) the prosecutor committed misconduct in opening/closing; and (4) cumulative error required reversal. The court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Judge commented on evidence	Abram: trial judge’s remark that the email exhibit had "potential" value improperly commented on weight of evidence.	State: remark was not prejudicial; judge may explain rulings and jury was instructed to disregard any opinion from the court.	Affirmed — no prejudicial comment; instruction cured any appearance of opinion.
Admissibility of prior bad acts (lying charge)	Abram: prior bad-act charge not resulting in conviction was inadmissible under Rule 404(b).	State: defense opened the door when Abram testified about never being charged with lying; impeachment was permissible.	Affirmed — court did not abuse discretion; impeachment allowed after door opened.
Prosecutorial misconduct (vouching, opinion, "send a message")	Abram: prosecutor vouched for Ishman, expressed personal belief and urged jurors to "send a message," requiring reversal.	State: arguments were reasonable advocacy; no objection at trial and statements did not create unjust prejudice.	Affirmed — comments within latitude of advocacy; any improper personal-belief remark was not objected to and did not create reversible prejudice.
Cumulative error	Abram: cumulative effect of errors deprived him of a fair trial.	State: individual claims lack merit, so no cumulative error.	Affirmed — no individual errors found, so no cumulative error.

McDowell v. State, 984 So. 2d 1003 (Miss. Ct. App. 2007) (failure to object to judge’s comment waives the issue on appeal)
Burnett v. State, 231 So. 3d 1001 (Miss. Ct. App. 2017) (trial judges may explain evidentiary rulings if not prejudicial)
Wells v. State, 698 So. 2d 497 (Miss. 1997) (limitations on judicial comment on evidence)
Cobb v. State, 734 So. 2d 180 (Miss. Ct. App. 1999) (presumption that juries follow trial-court instructions)
Underwood v. State, 708 So. 2d 18 (Miss. 1998) (evidence of unconvicted prior offenses generally inadmissible)
Council v. State, 976 So. 2d 889 (Miss. Ct. App. 2007) (defendant who puts character in issue opens door to impeachment)
Morgan v. State, 741 So. 2d 246 (Miss. 1999) (prosecution may rebut defendant’s assertions of good character)
Jackson v. State, 174 So. 3d 232 (Miss. 2015) (standard for reversal based on prosecutorial misconduct is unjust prejudice)
O'Connor v. State, 120 So. 3d 390 (Miss. 2013) (prosecutor’s argument so inflammatory that judge should sua sponte intervene)
Ross v. State, 954 So. 2d 968 (Miss. 2007) (cumulative-error doctrine requires reversal only if combined errors deny a fundamentally fair trial)