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State of West Virginia v. Harold D. Stambaugh, Jr.
16-0122
| W. Va. | Nov 18, 2016
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Background

  • Defendant Harold D. Stambaugh, Jr. was indicted for first-degree murder, burglary, and brandishing a firearm; a jury convicted him of first-degree murder and brandishing and acquitted him of burglary.
  • On November 7, 2014, police found the victim dead from multiple gunshot wounds at her mother's home and found Stambaugh with a gunshot wound to his mouth; a .40 caliber handgun (murder weapon) was recovered.
  • Stambaugh made statements to police acknowledging he could be the shooter but claiming memory gaps/blackouts; a suicide note referencing the victim’s mother was also found among his belongings.
  • Trial evidence included testimony about Stambaugh’s chronic heavy drinking and expert opinions: defense experts testified to memory impairment and impaired executive functioning; the State’s expert testified Stambaugh was capable of purposeful, sequential conduct.
  • The jury found Stambaugh guilty of first-degree murder but recommended mercy; the court sentenced him to life with the possibility of parole for murder and one year for brandishing.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Sufficiency of evidence to support first-degree murder (premeditation/deliberation) State: Evidence (confession statements, actions before/after killing, recovery of weapon, motive) supports a finding of premeditation and deliberate intent. Stambaugh: Memory impairment from chronic alcoholism prevented capacity to premeditate or deliberate; directed verdict should have been granted. Affirmed. Viewing evidence in the light most favorable to the State, a rational jury could find guilt beyond a reasonable doubt.
Exclusion of proposed expert testimony on blood alcohol concentration (BAC) State: Trial court properly exercised discretion in evidentiary rulings; admitted statutory BAC chart instead. Stambaugh: Trial court abused discretion by excluding expert testimony estimating BAC at time of killing. Not reviewed on appeal—issue was not preserved (defense counsel accepted exclusion and did not object), so appellate waiver applies.

Key Cases Cited

  • State v. Guthrie, 194 W. Va. 657, 461 S.E.2d 163 (1995) (standard for reviewing sufficiency of evidence and appellate deference to jury credibility determinations)
  • State v. McFarland, 228 W. Va. 492, 721 S.E.2d 62 (2011) (appellate function in sufficiency review: view evidence in light most favorable to prosecution)
  • State v. Dudley, 178 W. Va. 122, 358 S.E.2d 206 (1987) (unpreserved trial errors—failure to object waives appellate review)
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Case Details

Case Name: State of West Virginia v. Harold D. Stambaugh, Jr.
Court Name: West Virginia Supreme Court
Date Published: Nov 18, 2016
Docket Number: 16-0122
Court Abbreviation: W. Va.