Laterrence Lenoir v. State of Mississippi
222 So. 3d 273
| Miss. | 2017Background
- On Sept. 7, 2013, two masked men robbed a Dollar General in Brookhaven; surveillance video recorded the incident but was grainy and partially obscured.
- Victims Nettles and Calcotte testified about the robbery; manager Odum testified at trial that the man in the video was not Lenoir.
- Investigator Capt. Byron Catchings surveilled and identified Laterrence Lenoir as the first man in the video; Lenoir was charged with two counts of armed robbery and one count of conspiracy.
- Three witnesses familiar with Lenoir (Catchings, Willie Butler, Greta Mathis) testified that, based on familiarity—especially the defendant’s walk—Lenoir was the man in the video; another witness recanted a prior identification at trial.
- The jury convicted Lenoir on all counts; the trial court denied a motion for new trial. On appeal, Lenoir challenged (1) admission of Butler’s and Mathis’s lay-opinion identifications under M.R.E. 701 and (2) that the verdict was against the overwhelming weight of the evidence.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Lenoir) | Held |
|---|---|---|---|
| Admissibility of lay-opinion IDs under M.R.E. 701 | Opinion IDs by witnesses familiar with defendant are admissible if based on perception and helpful to jurors | Butler/Mathis lacked sufficient familiarity; IDs were nonspecific (based only on walk) and should be excluded | Admit testimony: trial court did not abuse discretion; familiarity goes to weight, not admissibility |
| Prejudice under M.R.E. 403 | Probative value (identity) outweighs any prejudice; bias affects weight | Testimony was unfairly prejudicial due to witness bias | No undue prejudice; admissible and for jury to weigh |
| Weight of the evidence (motion for new trial) | Jury could credit State witnesses and video; convictions supported | Verdict against overwhelming weight; evidence was slim and ambiguous | Denial of new trial affirmed; viewing evidence favorably to verdict, not an unconscionable injustice |
| Sufficiency of the evidence (raised sua sponte by dissent) | N/A at appellant level; standard requires viewing evidence most favorable to State—rational juror could convict | (Dissent) Evidence legally insufficient; video too pixelated and IDs too indefinite | Majority rejects sua sponte sufficiency challenge; declines to overturn verdict on that basis |
Key Cases Cited
- Bennett v. State, 757 So.2d 1074 (Miss. Ct. App.) (lay opinion ID may be admitted when witness has greater familiarity than jury)
- United States v. Jackman, 48 F.3d 1 (1st Cir.) (opinion IDs admissible if witness knows defendant better than jury and recording is neither unmistakably clear nor hopelessly obscured)
- Bishop v. State, 982 So.2d 371 (Miss. 2008) (admission of testimony reviewed for abuse of discretion)
- Bush v. State, 895 So.2d 836 (Miss. 2005) (standard for disturbing verdict on weight of evidence)
- Boyd v. State, 977 So.2d 329 (Miss. 2008) (appellate respect for jury’s resolution of credibility)