Richardson v. State
2014 Miss. LEXIS 310
| Miss. | 2014Background
- Richardson was charged with murder after shooting Quilon in Richardson's yard; the trial court granted a motion in limine to exclude Quilon’s prior violent acts and convictions; Richardson sought to admit evidence to show Quilon’s violent history to support his state of mind and reasonableness of his actions; Richardson argued the evidence was necessary to prove fear and self-defense; the court limited the 911 transcript and ruled evidence of Quilon’s past was inadmissible under Rule 609 and remote-time considerations; Richardson testified he feared Quilon due to his violent past and threats; the jury convicted Richardson of murder; the Mississippi Supreme Court reverses and remands for new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court erred by excluding Quilon’s prior violent acts. | Richardson argues the acts show Quilon’s violent history relevant to his state of mind. | State contends Rule 609 and prejudice outweigh probative value. | Yes, error; evidence relevant and admissible under Rule 404 for state of mind. |
| Whether Rule 609 applied to a dead victim’s history was misapplied. | Rule 609 does not apply because Quilon was dead and not a witness. | State relied on Rule 609 to exclude impeachment-like evidence. | Misapplied; Rule 609 inapplicable, yet error sustained for exclusion. |
| Whether exclusion of the evidence substantially impaired Richardson’s defense requiring reversal. | Knowledge of Quilon’s violence was crucial to Richardson’s self-defense claim. | Trial court properly weighed prejudicial effect over probative value. | Yes; exclusion significantly hampered defense; conviction reversed and remanded. |
Key Cases Cited
- Outerbridge v. State, 947 So.2d 279 (Miss.2006) (relevance and admissibility of prior acts in self-defense context cited by court)
- Smith v. Hollins, 905 So.2d 1267 (Miss.2005) (evidence rules and admissibility considerations under Miss. Rules of Evidence)
- Hart v. State, 637 So.2d 1329 (Miss.1994) (historical context of self-defense evidentiary standards in Mississippi)