Richard White v. State of Mississippi, 195 So. 3d 801

White was convicted of burglary of a dwelling in Quitman County and sentenced to 25 years' imprisonment.
The indictment alleged burglary with intent to commit larceny and/or assault; no party proposed jury instructions on larceny or assault elements.
The jury was instructed on burglary with intent to commit larceny and/or assault, and the jury acquitted White of aggravated assault.
Inmans identified White; a fingerprint matched White; tools were missing from the storage room.
White testified he was with family at home; no corroborating alibi witnesses were called; a rebuttal witness placed White at a different location earlier that day.
White argued, for the first time on appeal, that the circuit court failed to sua sponte instruct on the elements of larceny and/or assault.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the failure to sua sponte instruct on underlying offenses was plain error	White asserts the jury was not fully informed of the underlying offenses as required.	State contends the instructions, taken as a whole, sufficiently informed on the burglary intent and underlying offenses.	No plain error; instructions were sufficient when viewed as a whole.

Conner v. State, 138 So.3d 143 (Miss. 2014) (jury must be informed of the intended crime; intent to steal acceptable without listing all elements)
Daniels v. State, 107 So.3d 961 (Miss. 2013) (burglary requires intent to commit some specific crime; must be proven as second element)
Harrell v. State, 134 So.3d 266 (Miss. 2014) (capital murder underlying felony instructions reversible error; first step toward broader fairness)
Bolton v. State, 113 So.3d 542 (Miss. 2013) (plain error for failure to instruct on all essential elements of a crime)
Jones v. State, 164 So.3d 1009 (Miss. Ct. App. 2013) (Harmless/error analysis evolving; later affirmed under evolving doctrine)