State v. Juntilla
227 W. Va. 492
W. Va.2011Background
- Defendant Anthony Juntilla was convicted by jury of first degree murder (no mercy), sexual assault in the first degree, and conspiracy to commit sexual assault; sentences imposed life without parole, 15–35 years, and 1–5 years respectively, to run consecutively.
- The murder occurred May 26–27, 2007; the victim was T.S.; the Appellant claimed a companion, Douty, and the testimony implicated both in rape and murder.
- Ms. Brennan, the Appellant’s girlfriend, testified she was told by the Appellant about the Memorial Day weekend murder and provided details to police eventually leading to the body’s discovery.
- Douty testified as part of a plea agreement, detailing the events and the Appellant’s role; DNA evidence linked the Appellant to the scene, including a couch DNA mixture.
- The State’s case relied on Douty’s testimony, Brennan’s corroborating account, surveillance video, and DNA evidence; the defense challenged witness credibility and consistency.
- The circuit court denied motions for acquittal after the State’s case and after the defense rested; the jury returned guilty verdicts without a mercy recommendation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for acquittal | Juntilla argues insufficient evidence | State contends evidence supports guilt | Evidence sufficient; rational jury could find guilt beyond reasonable doubt |
| Admissibility of Appellant’s DNA statement | Statement obtained without Miranda warnings should be excluded | No interrogation; statement voluntary | Statement admissible; no Miranda violation |
| Strike of prospective juror for cause | Juror was biased against mercy; should have been excused | Juror could consider mercy; not biased | No error; trial court properly denied strike for cause |
| Guidelines for mercy in unitary first-degree murder trial | Court should provide mercy-guidance instructions | Such guidance should not be given, discretion to jury | No error; Miller governs mercy guidance not to be given in such trials |
Key Cases Cited
- State v. Guthrie, 194 W.Va. 657 (1995) (standard for sufficiency of evidence; jury credibility reserved to jury)
- State v. Miller, 178 W.Va. 618 (1987) (no mercy-guidance instruction in mercy determinations)
- State v. Newcomb, 223 W.Va. 843 (2009) (Miranda applicability when in custody and interrogation)
- State v. Stuart, 192 W.Va. 428 (1994) (standards for suppression and voluntariness of statements)
- State v. LaRock, 196 W.Va. 294 (1996) (standard for reviewing sufficiency of evidence on appeal)