Theotis Randle v. State of Mississippi
220 So. 3d 217
| Miss. Ct. App. | 2017Background
- Victim (pseudonym “Carol”), age 20, was alone at home when Randle, a handyman known to the family, forced her to the couch from behind and had sexual intercourse; she reported the incident and submitted to a rape kit.
- Randle initially denied sexual contact to police; a buccal swab taken from him later matched sperm found in Carol’s vaginal swab (DNA match).
- At trial Randle changed his story, claiming the intercourse was consensual and that they had a prior clandestine sexual relationship.
- A Clay County jury convicted Randle of sexual battery; he was sentenced to 25 years (5 years suspended) and ordered to register as a sex offender.
- Randle appealed, arguing (1) insufficiency/weight of the evidence, (2) witness sequestration violation (M.R.E. 615), (3) improper limitation of a defense witness and prejudicial courtroom comments, and (4) ineffective assistance of counsel.
- The Court of Appeals affirmed, finding the evidence (including DNA and victim testimony) supported the conviction, and rejecting the procedural and prejudice claims; ineffective-assistance claims were dismissed without prejudice for post-conviction review.
Issues
| Issue | Randle’s Argument | State’s Argument | Held |
|---|---|---|---|
| Sufficiency/weight of evidence | No proof Carol resisted; absence of injuries; prior sexual relationship supports consent | DNA linking Randle to vaginal sperm + victim testimony that she did not consent; credibility issues for Randle | Jury verdict supported; sufficiency and weight upheld |
| Witness sequestration (M.R.E. 615) | Deputy Williams improperly remained and heard other testimony, violating sequestration | Deputy Williams did not hear witness testimony; exclusion was granted when requested; no prejudice shown | No violation warranting reversal; no prejudice shown |
| Limitation of defense witness / judge’s comment | Ruling excluding witness from testifying about sexual relationship and judge’s remark prejudiced defense | Defense violated discovery and Rule 412; remedy was within court’s discretion; comment was non-prejudicial and not heard by jury | Exclusion appropriate as discovery violation; comment was incidental and not prejudicial |
| Ineffective assistance of counsel | Multiple trial errors (cross-exam, discovery, motions) amounted to ineffective assistance | Appellate record inadequate to resolve IAC; State declines to stipulate record sufficiency | Dismissed without prejudice; may be raised in post-conviction proceedings |
Key Cases Cited
- Bush v. State, 895 So. 2d 836 (Miss. 2005) (standard for sufficiency of the evidence)
- Jenkins v. State, 131 So. 3d 544 (Miss. 2013) (view evidence in light most favorable to verdict)
- Ambrose v. State, 133 So. 3d 786 (Miss. 2013) (jury resolves conflicts in testimony)
- Douglas v. State, 525 So. 2d 1312 (Miss. 1988) (sequestration rule and reversal requires showing of prejudice)
- Wilcher v. State, 863 So. 2d 776 (Miss. 2003) (appellate limits on resolving ineffective-assistance claims from the record)
- Archer v. State, 986 So. 2d 951 (Miss. 2008) (preferable resolution of IAC via post-conviction proceedings)