Sheila Ealey v. State of Mississippi, 158 So. 3d 283

Sheila Ealey gave birth alone in a motel room, wrapped the newborn in a comforter, placed the comforter in a trash bag inside a suitcase, and abandoned the suitcase behind her church; the infant was later found dead.
Ealey initially told investigators the pregnancy resulted from a rape and that she may have heard the baby cry once or twice; DNA later identified her longtime partner as the father.
Autopsy pathology later-opined cause of death "more likely than not" asphyxia and manner homicide; baby was in advanced decomposition when found.
Ealey admitted the conduct, asserted an insanity defense under the M’Naghten standard, and also sought an accident-or-misfortune jury instruction under Miss. Code §97-3-17(a).
Three mental-health experts agreed Ealey suffered depression and anxiety; none conclusively opined she met the M’Naghten test for legal insanity; lay witnesses testified she exhibited no odd behavior before or after the incident.
Jury convicted Ealey of capital murder (underlying felony: felonious child abuse) and the circuit court sentenced her to life without parole; she appealed raising three principal issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court erred by refusing accident-or-misfortune instruction	Ealey: evidence was inconclusive as to time/manner of death and her post-partum condition could support accidental death	State: facts show purposeful acts (wrapping, placing in suitcase, abandoning) and lack of evidence she acted with "usual and ordinary caution"	Denied — no evidentiary foundation; refusal not an abuse of discretion
Sufficiency of evidence for capital murder (child-abuse predicate)	Ealey: evidence supports only neglect/abandonment or poor judgment tied to depression, not felonious child abuse	State: confession, physical handling of infant, and expert opinion of asphyxia support intentional abusive acts causing serious bodily harm and death	Affirmed — evidence sufficient for capital murder conviction
Weight of the evidence / sanity finding	Ealey: depression evidence shows she was legally insane; verdict is contrary to weight of evidence	State: experts and lay testimony support that Ealey understood nature/wrongness of acts; M’Naghten was properly applied	Affirmed — jury’s sanity finding supported by substantial evidence; no unconscionable injustice
Whether Mississippi should abandon M’Naghten for Model Penal Code test	Ealey: urges adoption of MPC §4.01 as better test	State: adherence to precedent and stare decisis favors M’Naghten	Denied — Court declines to abandon M’Naghten (stare decisis)

Newell v. State, 49 So. 3d 66 (Miss. 2010) (standard for jury instruction review and limits on giving unsupported instructions)
Burge v. State, 472 So. 2d 392 (Miss. 1985) (statutory excusable homicide under Section 97-3-17)
Simmons v. State, 805 So. 2d 452 (Miss. 2001) (instructions must be supported by facts developed at trial)
Batiste v. State, 121 So. 3d 808 (Miss. 2013) (denial of instruction not error when evidence insufficient)
Robinson v. State, 758 So. 2d 480 (Miss. Ct. App. 2000) (refusal of accident instruction where evidence did not support accidental firing theory)
Beasley v. State, 136 So. 3d 393 (Miss. 2014) (legal-sufficiency standard: view evidence in light most favorable to verdict)
Bush v. State, 895 So. 2d 836 (Miss. 2005) (standard for weight-of-evidence review)
Buffington v. State, 824 So. 2d 576 (Miss. 2002) (acts of omission can constitute felony child abuse)
Woodham v. State, 779 So. 2d 158 (Miss. 2001) (M’Naghten test explained: knowing nature/quality or knowing wrongness)
Russell v. State, 729 So. 2d 781 (Miss. 1997) (jury’s province to decide sanity under M’Naghten)
Laney v. State, 421 So. 2d 1216 (Miss. 1982) (refusal to adopt Model Penal Code; reaffirming M’Naghten)
Burk v. State, 506 So. 2d 993 (Miss. 1987) (rejecting abandonment of M’Naghten)
Hill v. State, 339 So. 2d 1382 (Miss. 1976) (M’Naghten better protects society’s needs than MPC test)