Maurice Brown v. State of Mississippi, 235 So. 3d 1399

On July 30, 2015, Maurice Brown entered the home of 81-year-old Mattie Moore; her granddaughter Cheramie woke to find a man with a shotgun at her bedroom door.
Cheramie identified Maurice Brown in a photo lineup and testified he ordered her to "give me the stuff," took about $100 from her, handed the cash to his brother Jonathan, and kept the shotgun pointed at Cheramie and Mattie as they exited.
Jonathan Brown testified for the defense, claiming he alone took a cigar box and cigarettes and that neither brother had a gun; he said Maurice had been in the driveway and denied a weapon.
Maurice was indicted on two counts of armed robbery, tried, convicted for the armed robbery of Cheramie and acquitted of the count as to Mattie, and sentenced to 27 years.
Maurice moved for a directed verdict and later for JNOV or new trial; both were denied. The sole appellate issue was sufficiency of the evidence supporting the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to sustain armed robbery conviction	State: Cheramie’s eyewitness testimony established all elements—taking from person/presence, by putting her in fear with a shotgun	Brown: Jonathan’s testimony blamed himself and denied any gun; identification and physical evidence insufficient	Affirmed: viewing evidence in light most favorable to prosecution, jury could find guilt beyond a reasonable doubt
Whether jury should have credited defense witness over victim	State: jury entitled to believe Cheramie and reject Jonathan; a conflict is for the jury	Brown: jury should have discarded Cheramie’s testimony in favor of Jonathan’s account	Affirmed: conflicts in testimony do not warrant reversal; credibility is for the jury
Whether lack of physical evidence (e.g., fingerprints) defeats conviction	State: absence of physical evidence does not negate credible testimonial evidence	Brown: no physical evidence linking him to the crime	Rejected: testimonial evidence alone can support conviction
Whether single uncorroborated witness can sustain conviction	State: single credible witness sufficient	Brown: claimed identification only by Cheramie at trial was inadequate	Affirmed: single uncorroborated witness can sustain conviction

Bush v. State, 895 So. 2d 836 (Miss. 2005) (standard for reviewing sufficiency of evidence/Jackson framework)
Jackson v. Virginia, 443 U.S. 307 (1979) (conviction must be upheld if any rational trier of fact could find guilt beyond a reasonable doubt)
Lenoir v. State, 224 So. 3d 85 (Miss. 2017) (elements of armed robbery defined)
Cowart v. State, 178 So. 3d 651 (Miss. 2015) (armed robbery elements cited)
Hales v. State, 933 So. 2d 962 (Miss. 2006) (courts will not reweigh facts or invade jury’s province when factual conflicts exist)
Williams v. State, 512 So. 2d 666 (Miss. 1987) (a single uncorroborated witness can sustain a conviction)
Burleson v. State, 166 So. 3d 499 (Miss. 2015) (absence of physical evidence does not preclude conviction when testimonial evidence is sufficient)
Edwards v. State, 469 So. 2d 68 (Miss. 1985) (appellate remedy when evidence points strongly to defendant)
Hyde v. State, 413 So. 2d 1042 (Miss. 1982) (jury’s role in resolving disputed facts)
Holt v. State, 191 So. 673 (Miss. 1939) (single witness precedent)
Ragland v. State, 403 So. 2d 146 (Miss. 1981) (single witness can support conviction)