Renfro v. State
118 So. 3d 560
| Miss. | 2013Background
- Renfro was convicted of armed robbery under Miss. Code Ann. § 97-3-79 in Lincoln County.
- Andra Roundtree testified Renfro entered her trailer, threatened her with a gun, and demanded money.
- A second eyewitness corroborated most of Roundtree’s testimony; McCollum testified Renfro was present and demanded compliance.
- The gun and backpack Renfro allegedly took were not recovered; no physical evidence tied Renfro to the crime.
- Renfro did not testify; the defense emphasized credibility and gaps in police investigation.
- The jury returned a unanimous guilty verdict; Renfro challenged it as contrary to the weight of the evidence and sought a new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the verdict against the overwhelming weight of the evidence? | Renfro argues the verdict is against the weight of the evidence. | Renfro contends evidence was unreliable and insufficient to sustain guilt. | No; the verdict rested on substantial weight of evidence. |
| Did the State prove Renfro took or attempted to take Roundtree’s property and place her in fear by displaying a gun? | State contends evidence supports taking the gun and backpack and creating fear. | Renfro argues inconsistencies and lack of physical evidence undermine the two elements. | Yes; evidence supported both elements and was properly weighed by the jury. |
| Did the excluded evidence about Roundtree’s aggravated-assault indictment affect the conviction? | State argues exclusion did not preclude credibility evaluation. | Renfro claims impeachment evidence could have affected verdict. | No; exclusion did not mandate a new trial given overall evidence and credibility assessment. |
Key Cases Cited
- Williams v. State, 512 So.2d 666 (Miss.1987) (single uncorroborated witness sufficient for conviction)
- Duncan v. State, 939 So.2d 772 (Miss.2006) (inconsistencies do not require rejection of all witness testimony)
- Glidden v. State, 74 So.3d 342 (Miss.2011) (jury weighs evidence and credibility; weight for jury)
- Bush v. State, 895 So.2d 836 (Miss.2005) (new trial standard—weight of evidence considered)
- Dilworth v. State, 909 So.2d 731 (Miss.2005) (rare cases where weight justifies new trial)
- Lambert v. State, 462 So.2d 308 (Miss.1984) (exclusive province of jury to weigh credibility)
- Amiker v. Drugs For Less, Inc., 796 So.2d 942 (Miss.2000) (new trial where evidence preponderates against verdict)
- Mohr v. State, 584 So.2d 426 (Miss.1991) (jury may draw reasonable inferences from evidence)
- Thomas v. State, 129 Miss. 332, 92 So. 225 (1922) (early articulation of weight-of-evidence considerations)
- Lambert v. State, 462 So.2d 308 (Miss.1984) (credibility determinations reserved to jury)