State of West Virginia v. Ronald C. Davis, 232 W. Va. 398

Petitioner Ronald C. Davis was convicted by jury of first-degree murder and first-degree arson for a fatal fire at Parsons’ mobile home; he received life without parole on murder and 20 years on arson, consecutive.
Parsons died from smoke inhalation and thermal burns; fire started on the front porch and investigators recovered evidence inconsistent with some defense theories.
During the investigation, Davis made several statements; Lt. Metz conducted non-custodial questioning at the scene, and later Davis gave a recorded statement after warnings.
A preliminary hearing was held under Rule 5.1 to determine probable cause; Davis challenged the handling of witnesses and discovery-like questioning at the hearing.
Defense sought to introduce twenty tape-recorded conversations with Parsons to show a motive against Parsons’ daughter and son-in-law; court limited playback as hearsay and unwarranted by evidence.
Davis moved for mistrial over certain testimony and procedures; the circuit court ruled there was no manifest necessity for mistrial and instructed the jury to disregard some testimony.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Preliminary hearing questioning constraints valid?	State argued magistrate properly limited testimony to probable cause.	Davis claimed improper cross-examination and discovery overreach at the hearing.	No reversible error; constraints proper to probable cause focus
Admission of Alvin Turner testimony was improper?	State contends admission was within discretion and no manifest harm.	Davis asserted error in striking/mistrial decision due to misalignment with prior statements.	No abuse of discretion; ruling within trial court’s discretion
Failure to admit tape-recorded statements	State argued recordings were relevant but portions were properly excluded as hearsay and cumulative.	Davis sought admission of recordings to show lack of acrimony and motive by others.	Rulings upheld; remaining calls not admitted as irrelevant/hearsay
Mistrial requested after witness testimony was found incorrect	State argued corrective action and limiting instruction cured any potential prejudice.	Davis contended mistrial required due to erroneous testimony.	No manifest necessity; no reversal
Suppression of statements and custodial interrogation	State argued initial scene questioning was non-custodial and voluntary; Miranda warnings not required then.	Davis asserted custodial interrogation and required Miranda warnings for all responses.	Initial questioning non-custodial; statements admissible; later custodial warnings required for subsequent statements

State v. Vance, 207 W. Va. 640 (2000) (two-pronged deferential standard of review; abuse of discretion for new-trial rulings; clearly erroneous factual findings; de novo law)
State v. Desper, 173 W. Va. 494 (1984) (preliminary examination focuses on probable cause; discovery by-product exception)
State v. Lacy, 196 W. Va. 104 (1996) (suppression rulings reviewed for clear error; factual findings given deference)
State v. Stuart, 192 W. Va. 428 (1994) (deferential review of suppression conclusions; credibility deference)
State v. Middleton, 220 W. Va. 89 (2006) (custody factors for Miranda analysis; non-custodial scene questioning)
State v. Osakalumi, 194 W. Va. 758 (1995) (duty to preserve evidence; balancing missing evidence against probative value; Osakalumi doctrine)
State v. Lanham, 219 W. Va. 710 (2006) (crime-scene preservation; destruction of evidence; Osakalumi context)
State v. Thomas, 187 W. Va. 686 (1992) (preservation of documentation for tests; exculpatory evidence due process concern)
State v. Hatfield, 169 W. Va. 191 (1982) (due process; exculpatory evidence)
State v. Neuman, 179 W. Va. 580 (1988) (advising defendant of rights to testify; voluntary waiver considerations)
State v. Guthrie, 194 W. Va. 657 (1995) (jury instructions must reflect law; whole-charge approach)
State v. Collins, 154 W. Va. 771 (1971) (instructions must be supported by evidence)