William B. Wells v. State of Mississippi
2016-KA-00959-SCT
| Miss. | Oct 5, 2017Background
- On August 3, 2015, William B. Wells shot and killed Kendrick Brown in front of the Madison County Courthouse; Brown was unarmed and later died.
- Wells did not flee; deputies found him standing over Brown pointing a gun; he complied with commands to drop the gun and lie down.
- The State filed multiple motions in limine seeking to exclude: (1) Wells’s out-of-court statements around the shooting, (2) evidence of Brown’s prior convictions, (3) hearsay warnings that Brown had put a hit on Wells’s mother (Sherry), and (4) testimony that Brown tried to recruit someone to kill Sherry.
- Wells proffered evidence (through witnesses and a proffered statement) that his mother had served as a confidential informant, had been threatened and shot at on August 1, 2015, and that Wells had received street-level reports that Brown offered money to have Sherry killed.
- The circuit court granted the State’s motions in limine, excluded that proffered evidence as irrelevant or more prejudicial than probative under Rules 401–403, and refused instructions on self-defense/defense of others; the jury convicted Wells of first-degree murder.
- On appeal Wells argued the in limine rulings deprived him of due process and prevented presentation of self-defense, manslaughter, and related theories; the Mississippi Supreme Court affirmed.
Issues
| Issue | Plaintiff's Argument (Wells) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether in limine rulings denied Wells due process and a fair opportunity to present his defense | Excluding witness testimony, prior-conduct evidence, and out-of-court statements prevented him from showing his state of mind and defenses | The excluded evidence was irrelevant or double-hearsay and would be unfairly prejudicial and confusing | Court held no due-process violation; exclusion was within trial court discretion |
| Whether exclusion deprived Wells of right to assert self-defense/defense of others | Evidence of threats to Wells’s mother and street reports that Brown sought a hit made defense theory viable | No evidence showed any imminent danger or overt act by Brown at time of shooting; so defense instruction was unsupported | Court held self-defense/defense-of-others unavailable—no imminent danger—so exclusion proper |
| Whether exclusion barred manslaughter/heat-of-passion theory | The buildup of threats and fear would show sudden passion reducing culpability | There was no immediate provocation or uncontrollable rage at the time of shooting | Court held manslaughter/heat-of-passion not supported by evidence; exclusion proper |
| Whether granting the State’s motions in limine was an abuse of discretion | Rulings prevented admission of probative evidence about motive and state of mind | Motive/state-of-mind evidence was either double hearsay, irrelevant to imminence, or more prejudicial than probative | Court held motions in limine appropriately granted under Rules 401–403 and did not unduly restrict Wells’ case |
Key Cases Cited
- Evans v. State, 25 So. 3d 1054 (Miss. 2010) (standard for granting motions in limine and admissibility review)
- Whittley v. City of Meridian, 530 So. 2d 1341 (Miss. 1988) (motions in limine should not unduly restrict a party’s presentation)
- Wadford v. State, 385 So. 2d 951 (Miss. 1980) (self-defense requires evidentiary support)
- Lentz v. State, 604 So. 2d 243 (Miss. 1992) (objective reasonable-person standard for imminent danger)
- Maye v. State, 49 So. 3d 1124 (Miss. 2010) (presence of a third party alone does not justify defense-of-others instruction)
- Neal v. State, 15 So. 3d 388 (Miss. 2009) (manslaughter/heat-of-passion requires immediate provocation)
- Hobson v. State, 730 So. 2d 20 (Miss. 1998) (defining heat-of-passion manslaughter and provocation elements)