Antwaine Liddell v. State of Mississippi

CourtCourt of Appeals of Mississippi
DecidedJanuary 8, 2019
Docket2016-KA-01656-COA
StatusPublished

This text of Antwaine Liddell v. State of Mississippi (Antwaine Liddell v. State of Mississippi) is published on Counsel Stack Legal Research, covering Court of Appeals of Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Antwaine Liddell v. State of Mississippi, (Mich. Ct. App. 2019).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2016-KA-01656-COA

ANTWAINE LIDDELL A/K/A ANTWAINE APPELLANT MAURICE LIDDELL

v.

STATE OF MISSISSIPPI APPELLEE

DATE OF JUDGMENT: 11/14/2016 TRIAL JUDGE: HON. M. JAMES CHANEY JR. COURT FROM WHICH APPEALED: SHARKEY COUNTY CIRCUIT COURT ATTORNEY FOR APPELLANT: OFFICE OF STATE PUBLIC DEFENDER BY: ERIN ELIZABETH BRIGGS ATTORNEY FOR APPELLEE: OFFICE OF THE ATTORNEY GENERAL BY: ALICIA MARIE AINSWORTH DISTRICT ATTORNEY: RICHARD EARL SMITH JR. NATURE OF THE CASE: CRIMINAL - FELONY DISPOSITION: AFFIRMED - 01/08/2019 MOTION FOR REHEARING FILED: MANDATE ISSUED:

EN BANC.

WESTBROOKS, J., FOR THE COURT:

¶1. Following a jury trial, Antwaine Liddell was convicted in the Sharkey County Circuit

Court on seven counts: one count of deliberate design murder, one count of burglary of a

dwelling, one count of armed robbery, three counts of kidnaping, and one count of

conspiracy to commit armed robbery. Subsequently, he was sentenced to life plus fifty years

in the custody of the Mississippi Department of Corrections (MDOC). Aggrieved, Liddell

filed a motion for a judgment notwithstanding the verdict (JNOV) or, in the alternative, a

new trial. The circuit court denied Liddell’s motion. He now appeals. Finding no reversible error, we affirm.

FACTS

¶2. In March 2014, Eric Williams Sr. was killed at his home during a burglary. Liddell

and five others were indicted in Sharkey County for the crime. In August 2016, Liddell’s

motion for a change of venue was granted,1 and venue was transferred to the Forrest County

Circuit Court. After a jury trial in October 2016, Liddell was convicted on seven counts: (1)

deliberate design murder, (2) burglary of a dwelling, (3) armed robbery, (4 -6) kidnaping, and

(7) conspiracy to commit armed robbery. Liddell was sentenced to life on count I, fifteen

years on count 2, twenty years on count 3, ten years on count 4, ten years on count 5, ten

years on count 6, and five years on count 7. The circuit court ordered that counts 4, 5, and

6 be served concurrently with each other and consecutively to counts 1, 2, 3, and 7, which

are to be served consecutively to each other, totaling a life sentence plus fifty years.

¶3. Liddell filed a motion for JNOV or, in the alternative, a new trial. The circuit court

denied his motion, and he timely appeals.

STANDARD OF REVIEW

¶4. In reviewing a motion for JNOV or a motion for a new trial, this Court has held that:

A motion for JNOV challenges the sufficiency of the evidence presented to the jury. The critical inquiry is whether the evidence shows beyond a reasonable doubt that the accused committed the act charged, and that he did so under such circumstances that every element of the offense existed. This Court’s standard of review is to analyze the evidence in the light most favorable to the

1 Frank Finley, a co-conspirator, was granted a change of venue after voir dire because there were not enough impartial jurors to comprise a jury. The circuit court granted Liddell’s motion anticipating the same issue due to the “common knowledge, family connections and employment issue in [the] small rural community.”

2 prosecution, and decide if any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt. The appellee receives the benefit of all favorable inferences that may be reasonably drawn from the evidence. Furthermore, all credible evidence supporting the verdict will be accepted as true. This Court will reverse on the issue of legal sufficiency of the evidence when the facts favor the appellant to such an extent that reasonable men could not have found appellant guilty. However, this Court is required to affirm the judgment of the trial court on the sufficiency of the evidence where substantial evidence of such quality and weight exists to support the verdict and where reasonable and fair minded jurors may have found appellant guilty.

Sacus v. State, 956 So. 2d 329, 334 (¶12) (Miss. Ct. App. 2007) (citations and internal

quotation marks omitted).

Alternatively, unlike a motion for JNOV, a motion for a new trial challenges the weight, not the sufficiency, of the evidence. This Court will review the trial court’s denial of a motion for a new trial under an abuse of discretion standard. This Court will only disturb a verdict when it is so contrary to the overwhelming weight of the evidence that to allow it to stand would sanction an unconscionable injustice. The evidence will be analyzed in the light most favorable to the verdict.

Id. at (¶13) (citations and internal quotation marks omitted).

DISCUSSION

I. Whether the trial court erred in overruling Liddell’s hearsay objections.

¶5. Liddell asserts that the circuit court erred in allowing three witnesses to introduce

inadmissible hearsay testimony. “The standard of review regarding admission or exclusion

of evidence is abuse of discretion.” Tillis v. State, 176 So. 3d 37, 45 (¶15) (Miss. Ct. App.

2014). “Where error involves the admission or exclusion of evidence, this Court will not

reverse unless the error adversely affects a substantial right of a party.” Id. “Unless the trial

court has so abused this discretion as to prejudice the defendant’s case, we will not reverse

3 the ruling of the trial court.” Id. “We employ a de novo standard of review when presented

with constitutional issues.” Id.

A. Lacarius Oliver and Rusty Clark

¶6. Liddell asserts that the circuit court erred in allowing Investigators Lacarius Oliver’s

and Rusty Clark’s testimonies because certain statements were hearsay and did not meet any

exception. Hearsay is an out-of-court statement made by the declarant that is offered into

evidence to prove the truth of the matter asserted. See M.R.E. 801. This Court has held that:

An officer’s testimony being offered to explain why he or she acted as he or she did, and not for the truth of the matter asserted, is not hearsay and is admissible. Information obtained in the course of an investigation is admissible when it is for providing the basis of the investigation and ultimate arrest of the defendant.

Jefferson v. State, 214 So. 3d 1071, 1078 (¶19) (Miss. Ct. App. 2016) (citations omitted).

¶7. The statements of Investigators Oliver and Clark are not hearsay. Liddell’s

assignments of error stem from three statements made by Oliver about receiving information

from another investigator, a lead sheet from an anonymous phone call, and an interview of

Brandon Gilmore’s wife. In the first statement, Oliver responded, “I want to say the other

investigator told me that, but it was . . .” after being asked how information about residents

from Copiah County were involved in the incident. We find that this statement was properly

admitted because Oliver was describing why he turned his attention to residents in Copiah

County next in his investigation and it was not offered for the truth of the matter asserted.

¶8. The second assignment of error arose from the line of questioning about the lead

sheet. Once again, we find that Oliver’s testimony was properly admitted because it was a

4 part of his investigation and was not offered to assert the veracity of the contents of the lead

sheet.

¶9.

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Related

Williams v. State
919 So. 2d 250 (Court of Appeals of Mississippi, 2005)
Smith v. State
984 So. 2d 295 (Court of Appeals of Mississippi, 2007)
Smith v. State
986 So. 2d 290 (Mississippi Supreme Court, 2008)
Johnson v. State
956 So. 2d 358 (Court of Appeals of Mississippi, 2007)
Kendrick D. Smith v. State of Mississippi
158 So. 3d 1182 (Court of Appeals of Mississippi, 2015)
Anthony Davon Jefferson v. State of Mississippi
214 So. 3d 1071 (Court of Appeals of Mississippi, 2016)
Lawrence v. State
116 So. 3d 156 (Court of Appeals of Mississippi, 2012)
Tillis v. State
176 So. 3d 37 (Court of Appeals of Mississippi, 2014)
Sacus v. State
956 So. 2d 329 (Court of Appeals of Mississippi, 2007)

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Bluebook (online)
Antwaine Liddell v. State of Mississippi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/antwaine-liddell-v-state-of-mississippi-missctapp-2019.