Ralph Edward Lloyd v. State of Mississippi, 237 So. 3d 833

On Oct. 15, 2015, Arthur Luckett was robbed at gunpoint by four masked men; $500 and a money order were taken.
Police investigation identified Kendoirus Hobson (a known former informant) and a teenager, Willie Louis (“Willow”), as witnesses; Willow later pleaded guilty to simple robbery in exchange for his testimony implicating Ralph Edward Lloyd (“Dirt”).
Hobson testified he observed Lloyd distribute masks and saw the group prepare to commit the robbery; Willow testified Lloyd participated and handed out masks, though Willow changed stories multiple times and admitted lying earlier.
No physical evidence linked Lloyd to the robbery; police questioned but did not charge Hobson.
A jury convicted Lloyd of armed robbery and conspiracy; he was sentenced to 45 years (10 suspended) plus a five-year firearm enhancement, and five years for conspiracy, all concurrent. The trial court denied Lloyd’s new-trial/JNOV motion, and Lloyd appealed.

Issue	Lloyd’s Argument	State’s Argument	Held
Whether counsel was ineffective for failing to request an accomplice cautionary jury instruction	Counsel performed deficiently by not requesting the instruction when conviction rested on accomplice testimony; prejudice likely changed outcome	No instruction required because Willow’s testimony was corroborated by Hobson, who was not an accomplice; counsel’s omission harmless	Counsel’s failure was deficient, but Lloyd failed to show Strickland prejudice; conviction affirmed
Whether Willow and/or Hobson were accomplices requiring mandatory cautionary instruction	Willow and Hobson were accomplices; their testimony was the sole basis for conviction	Hobson was not an accomplice (not charged), so his testimony corroborated Willow	Court treated Willow as an accomplice but found Hobson’s testimony provided corroboration; instruction not mandatory in these circumstances

Goldsmith v. State, 195 So. 3d 207 (Miss. Ct. App. 2016) (standard for reviewing denial of motion for new trial and ineffective-assistance framework)
Carson v. State, 212 So. 3d 22 (Miss. 2016) (accomplice-testimony cautionary-instruction principles)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance of counsel)
Stringer v. State, 454 So. 2d 468 (Miss. 1984) (Mississippi adoption of Strickland)
Jones v. State, 203 So. 3d 600 (Miss. 2016) (defendant entitled to cautionary instruction if accomplice testimony is uncorroborated)
Brewer v. State, 725 So. 2d 106 (Miss. 1998) (definition of accomplice as person implicated in commission of a crime)