Stanley Ross Strickland v. State of Mississippi
215 So. 3d 514
| Miss. Ct. App. | 2017Background
- Defendant Stanley Ross Strickland, age 38, was convicted of two counts of statutory rape for sexual intercourse with his biological daughter S.T., who was 15 at the time.
- Incidents occurred in April 2012; sexual acts occurred on at least two separate occasions, with condoms used. Defendant also forced the victim to use drugs/alcohol and threatened to kill her if she told.
- Victim’s mother discovered inappropriate text messages from Strickland to S.T., continued the texts posing as S.T., and provided them to law enforcement. Texts corroborated timing and substance of the encounters.
- Department of Human Services investigator and a deputy sheriff testified about victims’ reports and that messages originated from Strickland’s phone number.
- Strickland was sentenced to consecutive thirty-year terms on each count (sixty years total), without parole; he appealed asserting insufficient evidence and related trial-errors. The Court of Appeals affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether denial of directed verdict was error (sufficiency of evidence) | State: testimony, corroborating text messages, DHS investigator support guilt beyond reasonable doubt | Strickland: victim’s in-court statements contain date inconsistencies; evidence insufficient | Affirmed — viewing evidence in State's favor, sufficient evidence supported guilty verdict |
| Whether denial of peremptory instruction was error | State: evidence and reasonable inferences supported jury verdict | Strickland: asserted evidentiary basis for acquittal due to inconsistencies | Affirmed — enough evidence existed that reasonable jurors could convict |
| Whether denial of motion for new trial was error (weight of evidence) | State: weight and credibility questions for jury; no unconscionable injustice | Strickland: verdict against overwhelming weight of evidence due to inconsistencies | Affirmed — trial court did not abuse discretion; verdict not contrary to overwhelming weight |
Key Cases Cited
- Singleton v. State, 948 So. 2d 465 (Miss. Ct. App. 2007) (standard for directed verdict/JNOV and review of sufficiency of evidence)
- Williams v. State, 863 So. 2d 63 (Miss. Ct. App. 2003) (standard for peremptory instructions and acceptance of State’s evidence on review)