127 So. 3d 1124
Miss. Ct. App.2013Background
- Patterson was convicted of murder by the Scott County Circuit Court and sentenced to life in MDOC custody.
- Witnesses testified Patterson shot Guy without provocation, including multiple accounts of two head shots and no evidence of self-defense or malice mitigation.
- Patterson challenged the verdict on seven grounds, including manslaughter instruction, ineffective assistance, insanity-defense preclusion, competency, sufficiency and weight of the evidence, and cumulative errors.
- Before trial, Patterson sought to raise an insanity defense; the court precluded it for failure to timely notice under Rule 9.07, with some discussion of voluntary intoxication.
- A competency hearing found Patterson competent to stand trial; expert testimony noted memory loss related to alcohol but not a psychiatric incapacity.
- The verdict and judgment were ultimately affirmed on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Manslaughter instruction denial | Patterson sought a manslaughter instruction on lack of malice/design. | Patterson contends there was evidentiary basis for manslaughter. | No evidentiary basis; court acted within discretion; instruction refused. |
| Insanity defense preclusion | Rule 9.07 notice was timely or the sanction excessive; Sixth/Fifth Amendment rights violated. | Late or insufficient notice; insanity defense not viable given voluntary intoxication law. | Preclusion proper; no due-process or compulsory-process violation; intoxication not a defense. |
| Competency to stand trial | Patterson’s memory loss impaired ability to assist counsel and testify. | Evidence did not show probability of inability to conduct a rational defense. | Trial court did not abuse its discretion; Patterson competent to stand trial. |
| Sufficiency of the evidence | Evidence insufficient to prove murder with deliberate design. | Eyewitness testimony supported deliberate design beyond reasonable doubt. | Sufficient evidence supported murder verdict. |
| Weight of the evidence | Verdict against the overwhelming weight of the evidence. | Jury weighed conflicting testimony; no reversal required. | Verdict not against the overwhelming weight of the evidence; no new trial warranted. |
Key Cases Cited
- Victory v. State, 83 So.3d 370 (Miss. 2012) (jury instruction discretion and fairness considerations)
- Bridges v. State, 807 So.2d 1228 (Miss. 2002) (competency and due process considerations in competency findings)
- Adams v. State, 62 So.3d 432 (Miss. Ct. App. 2011) (voluntary intoxication not a defense)
- Bush v. State, 895 So.2d 886 (Miss. 2005) (standard for sufficiency and weight of evidence review)
- Hobson v. State, 730 So.2d 20 (Miss. 1998) (lesser-included offenses and evidentiary basis)
- State v. Swanson, 572 F.2d 523 (5th Cir. 1978) (amnesia and competency in amnesiac defendants; continuance considerations)
- Morris v. State, 301 S.W.3d 281 (Tex. Crim. App. 2009) (amnesia not per se incompetency; evaluation of memory loss in trial)