Tameshia Shelton v. State of Mississippi
214 So. 3d 250
| Miss. | 2017Background
- On October 16, 2009, Daniel Young was found shot to death near Tameshia Shelton’s trailer in Clay County, Mississippi; a .22 caliber handgun owned by Shelton was recovered at the scene.
- Shelton admitted she showed and cleaned the handgun earlier that day and, in multiple interviews, said she had loaded it before Young was shot; she initially told 911 the shooting was accidental.
- Forensic testing: bullet matched Shelton’s handgun; gun fired from contact or near-contact to Young’s chest; gunshot-residue (GSR) particles were found on Shelton’s hands and pajamas and on the backs of Young’s hands.
- Investigators observed signs of a scuffle in the driveway and recovered a hair clip with hair; officers described Shelton as distraught and repeatedly wiping her hands after the shooting.
- Shelton asserted amnesia and later suggested police tampered with evidence; she was indicted for murder and convicted by a jury on July 17, 2015, receiving life imprisonment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to support murder conviction | State: forensic evidence + admissions (loading gun) + GSR + scuffle support finding Shelton shot Young with deliberate design | Shelton: alternative theories (accident, suicide, or that she didn’t fire) and claimed amnesia, challenged inference from circumstantial evidence | Affirmed — evidence sufficient for a rational jury to find all elements beyond a reasonable doubt |
| Verdict against the weight of the evidence | State: combined forensic and testimonial evidence strongly supports conviction | Shelton: verdict is contrary to overwhelming weight and inconsistent with her account | Affirmed — verdict not so contrary to overwhelming weight to constitute injustice |
| Refusal of two-theory (alternative-hypotheses) jury instruction | Shelton: record supported multiple hypotheses and court should instruct jury on two-theory standard | State: court’s circumstantial-evidence instruction and other instructions adequately covered the law | Affirmed — trial court did not abuse discretion in refusing the instruction because circumstantial-evidence instruction fairly announced the law |
| Self-defense or suicide as justification/explanation | State: trajectory, contact wound, and witness testimony undermined suicide/self-defense; no evidence of justification | Shelton: suggested possible accident or other explanations (including suicide or that she didn’t fire) | Held: No evidence supported self-defense or suicide; jury reasonably rejected those theories |
Key Cases Cited
- Bush v. State, 895 So. 2d 836 (Miss. 2005) (standard for reviewing sufficiency and weight of evidence)
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard that conviction must be sustainable by any rational trier of fact viewing evidence in prosecution’s favor)
- Roby v. State, 183 So. 3d 857 (Miss. 2016) (discussion of sufficiency review principles)
- McInnis v. State, 61 So. 3d 872 (Miss. 2011) (standard for reviewing refusal of jury instructions and two-theory instruction guidance)
- Goff v. State, 14 So. 3d 625 (Miss. 2009) (circumstantial-evidence instruction and two-theory instruction interplay)
- Kitchens v. State, 300 So. 2d 922 (Miss. 1974) (authority on two-theory instruction doctrine)