Young v. State
99 So. 3d 189
Miss. Ct. App.2011Background
- Young shot Otis Lee Morgan at a July 4, 2008 family reunion after dispute over Morgan's affair with Young's wife.
- Young armed himself in anticipation of confrontation, armed with a gun, and approached Morgan in the carport.
- Eyewitnesses testified Morgan had no weapon; shots were fired, with Morgan falling after the second shot.
- Shakitay Harris, a defense witness, testified that only Young had a gun before the shooting, while Morgan had no weapon.
- A videotaped police interview of Harris contradicted some trial testimony, leading to disputes over impeachment of the witness.
- Young was convicted of murder and sentenced to life in MDOC; post-trial motions for new trial or JNOV were denied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Impeachment of a hostile witness | Shakitay was a hostile witness and could be impeached with prior statements. | Impeachment of a defense witness was improper as it risked prejudicing the defense and violated hearsay rules. | Court did not abuse discretion; error not prejudicial; impeachment allowed but no reversible error. |
| Imperfect self-defense jury instruction | Defendant entitled to imperfect self-defense instruction as a theory of defense. | No evidentiary basis for imperfect self-defense given evidence showing premeditation and lack of malice. | Instruction properly denied; no reversible error. |
| Directed verdict and JNOV | Circuit court erred in denying directed verdict and JNOV. | Evidence viewed in State's favor supported murder beyond reasonable doubt. | Evidence sufficient to sustain murder conviction; rulings affirmed. |
| New trial | Verdict contrary to weight of evidence; jury failed to view self-defense claim. | Weight of the evidence supported the verdict; self-defense claims contradicted by witnesses. | Verdict not against the weight of the evidence; denial of new trial affirmed. |
Key Cases Cited
- King v. State, 994 So.2d 890 (Miss.Ct.App. 2008) (standard for abuse of discretion in evidentiary rulings; hostility requirement for impeachment)
- Bush v. State, 895 So.2d 836 (Miss. 2005) (directed verdict/JNOV standard; weight of the evidence principles)
- Newell v. State, 49 So.3d 66 (Miss. 2010) (standard for reviewing jury instructions; overall fairness of charge)
- Moore v. State, 859 So.2d 379 (Miss. 2003) (imperfect self-defense doctrine; malice and necessity elements)
- Wade v. State, 748 So.2d 771 (Miss. 1999) (definition of self-defense and related defenses in Mississippi law)
- Livingston v. State, 943 So.2d 66 (Miss.Ct.App. 2006) (analysis of jury instructions; articulating law of the case)
- Rubenstein v. State, 941 So.2d 735 (Miss. 2006) (comprehensive framework for evaluating jury instructions and trial court rulings)