Seales v. State, 2012 Miss. LEXIS 165

Seales was convicted of grand larceny after a jury trial in Neshoba County Circuit Court.
Seales challenged the confession’s admissibility and the denial of a directed verdict.
Arrest occurred September 4, 2009; a written confession was provided on September 9, 2009.
Rule 6.03 delay violated initial appearance timing, but voluntariness and Miranda waivers supported admissibility.
Baysinger and Adkins testified no threats or promises were made to Seales regarding the confession.
The State introduced testimony on pawn transactions showing Seales’s possession of the stolen property and concealment evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Confession suppression legality	Seales claims involuntary confession due to incubation and coercion.	State argues proper Miranda warnings and voluntary waiver; Rule 6.03 violation alone not suppressive.	No reversible error; confession admissible after valid waiver.
Sufficiency of evidence for grand larceny	State failed to prove taking from Hollingsworth; only possession shown.	Evidence showed possession and value; sufficient to prove larceny beyond reasonable doubt.	Sufficient evidence; conviction affirmed.

Jones v. State, 841 So.2d 115 (Miss. 2003) (scope of review for voluntariness of confessions; standard of review)
Lawrence v. State, 869 So.2d 353 (Miss. 2003) (initial appearance delay; analysis of Rule 6.03 violation)
Stokes v. State, 548 So.2d 118 (Miss. 1989) (confession admissibility review framework)
Alexander v. State, 610 So.2d 320 (Miss. 1992) (voluntariness of confessions; factual findings deferential standard)
Veal v. State, 585 So.2d 693 (Miss. 1991) (coercion findings not reversed on conflicting testimony)
Presley v. State, 994 So.2d 191 (Miss. Ct. App. 2008) (jury may evaluate credibility of inconsistent accounts)
Gunn v. State, 56 So.3d 568 (Miss. 2011) (value of property for larceny is market value at time of theft)