Stringer v. State
131 So. 3d 1182
| Miss. | 2014Background
- Zachary Stringer, a minor, was charged with murder after his younger brother Justin was fatally shot; jury convicted Zachary of the lesser-included offense of manslaughter.
- At the scene investigators found Justin seated with a shotgun between his legs, brain matter/skull fragments, blood spatter, a .25-06 rifle with Justin’s blood on it, a spent .25-06 casing in Zachary’s closet, and bloody prints/footprints linking Zachary to the area.
- Zachary gave three statements: initially that Justin shot himself; later (with counsel) that the rifle accidentally discharged after Zachary retrieved it to “talk” with Justin and that he staged the scene; a third statement included admitting he loaded the rifle after threatening Justin.
- Forensic testing: the medical examiner could not determine manner of death or bullet trajectory (skull fragmented); crime-lab testing showed projectile consistent with Zachary’s rifle and functional tests did not reproduce an accidental discharge; rifle had an unadjusted, relatively heavy trigger.
- Family witnesses described atypical post-death demeanor by Zachary (laughing, joking, comments suggesting lack of remorse), which the State argued supported culpability.
- Trial: court admitted 33 photographs (crime-scene, body, autopsy); jury rejected murder but convicted manslaughter; trial court sentenced Zachary to 20 years (10 to serve, 10 post-release) and denied post-trial motions. Appeal followed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of gruesome photographs | State: photos relevant to scene, body location, cause, and to clarify testimony | Zachary: photos were cumulative, unduly prejudicial, inflammatory, and unnecessary | Court: admitted photos were more probative than prejudicial; no abuse of discretion |
| Sufficiency of evidence (JNOV) — manslaughter (culpable negligence) | State: physical evidence, conflicting statements, and demeanor support conviction | Zachary: evidence proves only an accident; no culpable negligence; lack of trajectory proof | Court: viewing evidence in State’s favor, sufficient evidence of culpable negligence existed; denial of JNOV affirmed |
Key Cases Cited
- Davis v. State, 849 So.2d 1252 (Miss. 2003) (gruesome photos admissible when they aid description of angles/trajectories and clarify expert testimony)
- Baldwin v. State, 784 So.2d 148 (Miss. 2001) (trial court may limit number of photos but gruesome images that show extent/location of injuries can be admissible)
- McNeal v. State, 551 So.2d 151 (Miss. 1989) (reversal where photos were excessively inflammatory and alternative non-gruesome photos could show fatal wound)
- Bush v. State, 895 So.2d 836 (Miss. 2005) (standard for viewing evidence on JNOV: view credible evidence in the light most favorable to the State)
- Tait v. State, 669 So.2d 85 (Miss. 1996) (pointing a loaded gun at another can support manslaughter conviction as showing reckless disregard of fatal risk)
