Rothell Chambliss v. State of Mississippi
233 So. 3d 898
Miss. Ct. App.2017Background
- August–September 2015: Owner Michael Dubois discovered two burglaries of campers on his Fayette, MS property and installed cameras; later footage captured a man on the property.
- Deputy James Bailey processed the scene and collected latent prints; those prints were sent to the Mississippi Crime Laboratory.
- Mike Hood, forensic latent-prints chief, matched the crime-scene latent prints to Chambliss’s “known” prints from the Mississippi criminal-history database.
- October 2015: Grand jury indicted Rothell Chambliss for burglary of a dwelling and charged him as a habitual offender.
- February 2016: Jury convicted Chambliss; trial court sentenced him as a habitual offender to 25 years in MDOC, no parole/probation.
- Chambliss appealed raising (1) denial of a mistrial after a prospective juror referenced prior proceedings involving Chambliss, and (2) Confrontation Clause challenge to testimony about Chambliss’s “known” fingerprints.
Issues
| Issue | Chambliss’s Argument | State’s Argument | Held |
|---|---|---|---|
| Whether trial court erred by denying mistrial after a prospective juror mentioned prior testimony against Chambliss | Juror’s comment that he previously testified against Chambliss for a similar breaking-in tainted the panel and required a mistrial | The juror’s remark was brief, non-specific, and follow-up questioning plus instructions cured any prejudice; juror was not seated | Trial court did not abuse discretion; denial of mistrial affirmed |
| Whether admission of testimony that latent prints matched Chambliss’s “known” prints violated the Confrontation Clause | The ‘‘known’’ prints derive from a criminal-history database and the statement was testimonial hearsay prepared for prosecution, implicating Crawford/Melendez-Diaz protections | Fingerprints and routine booking records are nontestimonial; the fingerprint card was created for identification/administrative purposes, not specifically for prosecution | Admission was proper; no Confrontation Clause violation found; no plain-error shown |
Key Cases Cited
- Whitaker v. State, 114 So. 3d 725 (Miss. Ct. App. 2012) (voir dire taint and juror impartiality analysis)
- Tate v. State, 20 So. 3d 623 (Miss. 2009) (mistrial standard and trial-court discretion)
- Beasley v. State, 74 So. 3d 357 (Miss. Ct. App. 2010) (prejudice requirement for mistrial reversal)
- Jones v. State, 962 So. 2d 1263 (Miss. 2007) (deference to trial judge on juror bias)
- Benson v. State, 551 So. 2d 188 (Miss. 1989) (follow-up questioning can cure voir dire issues)
- Conners v. State, 92 So. 3d 676 (Miss. 2012) (Confrontation Clause is a fundamental right; plain-error review)
- Crawford v. Washington, 541 U.S. 36 (2004) (testimonial statements barred unless witness unavailable and prior cross-examination occurred)
- Bullcoming v. New Mexico, 564 U.S. 647 (2011) (forensic lab reports as core testimonial statements)
- Melendez-Diaz v. Massachusetts, 557 U.S. 305 (2009) (certificates of analysis treated as testimonial)
- Jenkins v. State, 102 So. 3d 1063 (Miss. 2012) (forensic reports and testimonial evidence discussion)
- Newton v. State, 321 So. 2d 298 (Miss. 1975) (fingerprints are not testimonial evidence)
- Maryland v. King, 133 S. Ct. 1958 (2013) (DNA/fingerprinting as routine administrative booking procedure)
- Rubenstein v. State, 941 So. 2d 735 (Miss. 2006) (Confrontation Clause applies only to testimonial hearsay)
- Anthony v. State, 23 So. 3d 611 (Miss. Ct. App. 2009) (failure to object at trial bars Confrontation Clause argument on appeal)
- Corbin v. State, 74 So. 3d 333 (Miss. 2011) (plain-error test for Confrontation Clause violations)