State of West Virginia v. Rashaun R. Boyd and Christopher R. Wyche
238 W. Va. 420
| W. Va. | 2017Background
- Early-morning shooting outside Brickhouse Bar (Sept. 16, 2012). Victim Samson Edmond was fatally shot; Antoine Stokes survived and identified the two petitioners at trial.
- Petitioners Rashaun R. Boyd and Christopher R. Wyche were jointly indicted and tried together; Jimmy Vick was a third occupant of Boyd’s car but not charged.
- Video and eyewitness testimony placed petitioners at the scene; Cadillac driven by Boyd fled and was later stopped in Maryland after a pursuit.
- Gunshot residue (GSR) testing of Boyd and Wyche was performed while they were in Maryland custody; GSR found on both but not on Vick.
- Jury convicted Boyd (attempted murder, wanton endangerment, possession of a firearm) and Wyche (voluntary manslaughter, wanton endangerment, possession of a firearm); recidivist findings added sentence enhancements.
- The trial court denied post-trial motions; the Supreme Court of Appeals of West Virginia affirmed on multiple grounds.
Issues
| Issue | State/Plaintiff Argument | Petitioners' Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence | Evidence (eyewitness ID, video, GSR, flight) sufficient when viewed in light most favorable to prosecution | Insufficient: no gun recovered; GSR explainable by post-arrest contact; alternative suspects not fully investigated | Affirmed: circumstantial evidence sufficed under Guthrie/Jackson standard |
| Motion to sever (joint trial) | Joint trial permissible; limiting instructions and compartmentalization cure spillover | Wyche: joint trial prejudiced him (spillover from Boyd wiping hands, flight, inability to compel Boyd to testify) | Denied: no abuse of discretion; severance only required for serious risk to specific trial right (Zafiro standard) |
| Peremptory strike (Batson) | Strike was race-neutral (pending DUI prosecution, hearing difficulty) | Wyche: State struck sole minority juror on racial grounds | Affirmed: trial court credited prosecutor; no clear error or Batson violation |
| GSR evidence admissibility & collection | GSR testing lawful (exigent/destructibility rationale); chain of custody sufficient; Miranda not implicated | Wyche: lack of warrant/consent, chain-of-custody gaps, Miranda violation, unfairly prejudicial | Admitted: routine GSR testing allowed incident to arrest/exigent circumstances; chain issues for jury; any jurisdictional error harmless beyond reasonable doubt |
| Brady / late disclosure | State provided materials in time for effective use; delayed items not materially favorable | Wyche: late disclosure of discovery, GSR protocols, investigator status (vomit DNA) prejudiced defense | Denied: no Brady violation shown (not favorable, suppressed, and material) and no reasonable probability of different outcome |
| Sequestration / State’s representative at counsel table | Rule 615(b) permits party to designate representative (investigative agent) to remain | Wyche: investigator’s presence prejudicial; should be sequestered or testify first | Affirmed: trial court acted within discretion; Rule 615(b) exception applies |
| Authentication of evidence (dash-cam, fingerprint records) | Video authenticated by custodial and observing officers; fingerprint records certified and matched by expert | Wyche: lack of direct custodian (Trooper Conner) for video; fingerprints not self-authenticating | Admitted: prima facie authentication satisfied for video; certified pen-packet/fingerprint records properly admitted under Rules 901/902 |
| Prosecutor’s closing remarks | Not preserved by contemporaneous objection | Wyche: remarks were inflammatory and warrant new trial | Waived: no timely objection; not plain error |
Key Cases Cited
- State v. Guthrie, 194 W. Va. 657 (W. Va. 1995) (standard for appellate review of sufficiency of the evidence)
- Zafiro v. United States, 506 U.S. 534 (U.S. 1993) (severance standard — serious risk of prejudice to specific trial right)
- Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (framework for challenging race-based peremptory strikes)
- State v. Parham, 200 W. Va. 609 (W. Va. 1997) (appellate deference to trial court Batson findings)
- State v. Charlot, 157 W. Va. 994 (W. Va. 1974) (chain-of-custody principles for physical evidence)
- Cupp v. Murphy, 412 U.S. 291 (U.S. 1973) (limited stationhouse procedures upheld where evidence is readily destructible)
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (constitutional sufficiency-of-evidence standard)
- State v. Youngblood, 221 W. Va. 20 (W. Va. 2007) (Brady three-part test)
- State v. Riley, 201 W. Va. 708 (W. Va. 1997) (GSR testing and Fourth Amendment analysis)