Richardson v. State, 2011 Miss. LEXIS 450

Richardson was convicted of capital murder and felon in possession of a firearm; the State sought the death penalty but the jury sentenced life without parole for capital murder, with consecutive ten-year sentence for the firearm conviction.
The underlying crime involved Richardson robbing Harvey Evans, striking him with a baseball bat, taking Evans's wallets, and using the money to purchase firearms the same day.
Witnesses testified Richardson bought two guns after the robbery, and others observed his conduct and statements indicating guilt and concern over Evans's condition.
Richardson confessed to investigators in a waivable Miranda setting; his statements were disputed by defense witnesses who claimed he requested counsel.
Richardson moved to suppress the statement, moved to sever Counts I and II, and moved in limine to exclude other-crimes evidence; the trial court denied these motions.
On appeal, the Mississippi Supreme Court affirmed, holding the suppression ruling, severance decision, admission of other-crimes evidence, and admission of a brain autopsy photograph were not reversible errors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Richardson's statement properly admitted?	Richardson contends he invoked counsel and was coerced.	State contends confession voluntary; no invocation of counsel were supported.	Statement admissible; no error.
Did the trial court abuse its discretion in denying severance of Counts I and II?	Counts are separate and unduly prejudicial; should be severed.	Counts are interwoven with common plan; severance not required.	No abuse; joinder proper; any error harmless.
Was the in limine exclusion of other-crimes evidence an abuse of discretion?	Other-crimes evidence should be excluded as prejudicial.	Evidence shows pecuniary motive and complete story; probative value outweighs prejudice.	No abuse; admissible 404(b) evidence; harmless.
Was the photograph of the victim's brain properly admitted?	Brain photograph is gruesome and prejudicial.	Photograph has probative value; redacted portions kept relevant.	Admissible; probative value outweighed prejudice.

Glasper v. State, 914 So.2d 708 (Miss.2005) (standard for reviewing voluntariness of confessions)
Corley v. State, 584 So.2d 769 (Miss.1991) (multicount indictments; Corley factors for severance)
Patrick v. State, 754 So.2d 1194 (Miss.2000) (time proximity supports joinder of offenses)
Williams v. State, 991 So.2d 593 (Miss.2008) (stipulation of prior conviction; limiting instruction when appropriate)
Armstead v. State, 978 So.2d 642 (Miss.2008) (multi-count indictments and not per se severance)
Golden v. State, 968 So.2d 378 (Miss.2007) (Corley considerations; evidence may be interwoven)
Conner v. State, 632 So.2d 1239 (Miss.1993) (pecuniary motive evidence admissible to tell complete story)
Davis v. State, 40 So.3d 525 (Miss.2010) (legitimate interest in telling rational story of crime)
Snelson v. State, 704 So.2d 452 (Miss.1997) (cocaine evidence post-robbery; prejudicial impact)
Mack v. State, 650 So.2d 1289 (Miss.1994) (caution with drug-evidence in motive cases; harmless error possible)