Rodney N. Robinson v. State of Mississippi
227 So. 3d 423
Miss. Ct. App.2017Background
- In October 2015 three men broke into Melvon Fason’s home; Fason (elderly, in poor health) testified three Black males entered and one wore dark/black clothing; two guns were taken.
- Officers found three men near nearby Southwood Apartments matching Fason’s general description; Robinson was the only one dressed all in black; the three were released after Fason could not make a positive in-person ID.
- The next day, co-defendant Joshua Johnson tried to sell a gun at a pawnshop, was detained, and gave a statement that he, Robinson, Davis, and another (Smith) had been involved; Johnson testified Robinson participated and that guns were stolen.
- Robinson was later interviewed, given Miranda warnings, and signed a written statement saying he was present that night, refused to enter the home, knew guns were stolen, and denied Smith’s presence.
- At trial the jury convicted Robinson of burglary of an occupied dwelling under circumstances likely to terrorize the occupant; because the victim was over 65, Robinson received an enhanced 35-year MDOC sentence. Robinson’s post-trial motion for JNOV/new trial was denied; he appealed arguing the verdict was against the overwhelming weight of the evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the conviction is against the overwhelming weight of the evidence | Robinson argued the State failed to prove guilt beyond a reasonable doubt because no physical evidence linked him to the burglary and Johnson had motive to implicate him | State argued corroborating evidence: Robinson admitted presence, knew guns were stolen, matched victim’s description (one in all black), and his statement corroborated parts of Johnson’s testimony; credibility and weight for the jury | Court affirmed: verdict not so contrary to overwhelming weight of the evidence to constitute unconscionable injustice; denial of new trial affirmed |
Key Cases Cited
- Bush v. State, 895 So. 2d 836 (Miss. 2005) (standard for overturning a verdict as against the overwhelming weight of the evidence)
- Danner v. State, 748 So. 2d 844 (Miss. Ct. App. 1999) (appellate scope when reviewing weight-of-evidence challenges)
- Williams v. State, 794 So. 2d 1019 (Miss. 2001) (jury is the final arbiter of witness credibility)
- Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda-warning requirements for custodial interrogations)