Wilson v. State
2012 Miss. LEXIS 327
| Miss. | 2012Background
- Wilson was convicted in Scott County for rape, burglary, extortion, and two kidnappings involving Jessica Goodwin and her infant Kaylee Alford.
- The offense occurred April 14–15, 2010, with Goodwin held at gunpoint, Kaylee taken, and extortion and rape committed by three men, including Pace.
- DNA testing linked sperm from Goodwin to Wilson via vaginal swabs and Wilson’s buccal swabs.
- Goodwin identified Wilson as the first assailant at trial; a single photograph was used for identification.
- Evidence included the rape kit, chain of custody testimony, and a 911 call in which Wilson confessed.
- The trial court denied motions for new trial and peremptory instructions; Wilson appealed raising multiple evidentiary and procedural issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admission of nurse’s hearsay about rape allegation | Wilson argues nurse Phillips’s testimony was hearsay | State contends 803(4) medical-diagnosis/treatment exception applies | Court allowed under Rule 803(4) as trustworthy for diagnosis/treatment |
| Chain of custody for rape kit and buccal swabs | Wilson asserts chain of custody was broken | State showed no probable tampering; burden not met | Court did not abuse discretion; no proven probable tampering |
| Sufficiency of evidence for kidnapping Kaylee Alford | Wilson made no effort to kidnap Kaylee; insufficiency | Totality of circumstances shows willful seizure and confinement | Sufficient evidence supports kidnapping conviction on Kaylee |
| Identification testimony by Goodwin without contemporaneous objection | Identification was tainted by single-photo procedure | No contemporaneous objection preserved issue; sufficiency remains | Issue preserved via sufficiency argument; no reversal; trial identification admitted |
Key Cases Cited
- Branch v. State, 998 So.2d 411 (Miss. 2008) (Rule 803(4) medical statements admissible when trustworthy)
- Simmons v. State, 722 So.2d 666 (Miss. 1998) (Emergency-room statements admissible for treatment)
- Deeds v. State, 27 So.3d 1135 (Miss. 2009) (Burden on chain-of-custody; substitution not presumed)
- Valmain v. State, 5 So.3d 1079 (Miss. 2009) (Identifying child’s assailant admissible in certain contexts)
- Madere v. State, 794 So.2d 200 (Miss. 2001) (Victim’s statements about fear admissible)
- Brown v. State, 829 So.2d 93 (Miss. 2002) (Preservation requirement for in-court identifications)
- Richardson v. State, 74 So.3d 317 (Miss. 2011) (Standard of review for evidentiary rulings)