Sands v. State, 62 So. 3d 374

Sands and Rhodes were tried for the killings of McInnis and Randolph Sands near the Church of Christ in Prentiss, Mississippi.
McNair testified Rhodes fired from the driver's side and Sands was seen with a small gun; no one testified Sands fired a weapon.
Multiple shots were fired; firearms recovered included .40 and .45 caliber guns, with shell casings traceable to specific weapons.
Rhodes was armed with a .45 pistol and fired at least five or six times; McInnis had a .40 caliber pistol.
Randolph Sands was killed with two close-range gunshot wounds to the back; Rhodes and McInnis were also wounded in the event.
The trial court later addressed juror misconduct, conducted voir dire, and denied a motion for a new trial; on appeal, the court reverses Sands’ convictions and affirms Rhodes’ convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to convict Sands of manslaughter and aggravated assault	Sands fired a shot; fingerprints point to Sands	No direct evidence Sands fired; lack of heat-of-passion evidence	Insufficient evidence; Sands’ convictions reversed and rendered
Sufficiency of evidence to convict Rhodes of murder and aggravated assault	Rhodes had deliberate design and fired multiple times	Deliberate design evidenced by prior confrontation and firing	Evidence sufficient; Rhodes’ convictions affirmed

Bush v. State, 895 So.2d 836 (Miss. 2005) (sufficiency review under Jackson v. Virginia standard)
Jackson v. Virginia, 443 U.S. 307 (1979) (establishes standard for reviewing sufficiency of evidence)
Edwards v. State, 469 So.2d 68 (Miss. 1983) (reiterates sufficiency framework and review)
Wilson v. State, 936 So.2d 357 (Miss. 2006) (defines elements of the murder statute and deliberation)