Young v. State, 2012 Miss. LEXIS 485

Lonnie Young killed Otis Morgan at a family reunion in 2008 and was convicted of murder, sentenced to life.
Appeals were pursued; the Court of Appeals affirmed, and the Mississippi Supreme Court granted certiorari to address two issues: impeachment of a witness and an imperfect-self-defense instruction.
Shakitay Harris, a key eyewitness and Young’s purportedly hostile witness, had given pretrial statements alleging Morgan had a gun, which conflicted with her trial testimony.
At trial, defense sought to impeach Harris with a videotaped police interview; the court allowed the tape to be shown but sustained a later objection to using it for impeachment.
The defense requested an imperfect-self-defense jury instruction; the trial court denied it, and the Court of Appeals affirmed, with the Mississippi Supreme Court granting certiorari to review these issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Impeachment of a hostile witness	Young argues Harris was hostile and deserved full impeachment.	State objected, arguing impeachment of a witness already cleared up misstatements.	Harmless error; impeachment deemed harmless given videotaped statement evidence.
Imperfect-self-defense instruction	Young contends imperfect self-defense instruction was warranted by the evidence.	State contends evidence did not support a bona fide but unfounded belief; instruction improper.	Denied; no basis for imperfect-self-defense instruction based on record.

Johnson v. State, 475 So.2d 1136 (Miss.1985) (instructional scope and burden in impeachment matters)
Hargett v. State, 62 So.3d 950 (Miss.2011) (admission or exclusion errors require substantial-right analysis)
Kolberg v. State, 829 So.2d 29 (Miss.2002) (harmless-error standard in evidentiary rulings)
State v. Gomaz, 141 Wis.2d 302, 414 N.W.2d 626 (Wis.1987) (discussed imperfect self-defense where perfect self-defense is charged)
Roach v. State, 358 Md. 418, 749 A.2d 787 (Md.2000) (imperfect self-defense and related doctrines)