State v. Woolridge-Jones
316 Neb. 500
Neb.2024Background
- Makhi Woolridge-Jones, 16 at the time, was charged in connection with a shooting at a Nebraska shopping mall in April 2021, resulting in one death (Trequez Swift) and one injury (Ja’keya Veland).
- He admitted to shooting Swift, claiming self-defense due to threats against him and his brother.
- Woolridge-Jones was charged with first degree murder, second degree assault, and two counts of use of a deadly weapon.
- At trial, he sought to admit psychological expert testimony (Dr. Conoley) that he experienced "peritraumatic dissociation" at the time of the shooting.
- The trial court excluded this expert testimony, and the jury convicted him of the lesser-included offense of second degree murder and other charges.
- He appealed, arguing (1) exclusion of expert testimony, (2) insufficiency of the evidence, and (3) excessive sentences.
Issues
| Issue | Woolridge-Jones' Argument | State's Argument | Held |
|---|---|---|---|
| Admissibility of Expert Testimony (Dissociation) | Dr. Conoley’s testimony would aid jury in assessing intent and whether acts were intentional | Testimony not relevant or adequately founded; would not assist trier of fact | Exclusion was not abuse of discretion; testimony would not assist on intent |
| Sufficiency of Evidence (Second Degree Murder) | Evidence did not support intent; actions were in response to perceived threat or accident | Sufficient evidence of intent to kill; jury could infer intent from actions | Sufficient evidence; conviction affirmed |
| Sufficiency of Evidence (Second Degree Assault) | Insufficient evidence he shot Veland or did so intentionally | Circumstantial evidence supports jury finding he shot Veland; transferred intent applies | Sufficient evidence under doctrine of transferred intent |
| Excessive Sentences | Sentences excessive given youth, background, mental health, and mitigating factors | Sentences within statutory limits, court considered all relevant factors | No abuse of discretion in sentencing |
Key Cases Cited
- State v. Braesch, 292 Neb. 930 (expert testimony must assist trier of fact on ultimate issue)
- State v. Stack, 307 Neb. 773 (appellate review of sufficiency of evidence; deference to factfinder)
- Scurlocke v. Hansen, 268 Neb. 548 (expert testimony requires sufficient factual foundation)
- State v. Johnson, 308 Neb. 331 (standard for appellate review of sentencing within statutory limits)
- State v. Morrow, 237 Neb. 653 (transferred intent doctrine in assault and homicide)