Eric Moffett v. State of Mississippi

CourtMississippi Supreme Court
DecidedOctober 13, 2022
Docket2018-DR-00276-SCT
StatusPublished

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

Bluebook
Eric Moffett v. State of Mississippi, (Mich. 2022).

Opinion

IN THE SUPREME COURT OF MISSISSIPPI

NO. 2018-DR-00276-SCT

ERIC MOFFETT

v.

STATE OF MISSISSIPPI

DATE OF JUDGMENT: 04/24/2014 TRIAL JUDGE: HON. W. SWAN YERGER COURT FROM WHICH APPEALED: HINDS COUNTY CIRCUIT COURT FIRST JUDICIAL DISTRICT ATTORNEYS FOR PETITIONER: OFFICE OF CAPITAL POST-CONVICTION COUNSEL BY: KRISSY CASEY NOBILE ELIZABETH ANNE FRANKLIN-BEST ATTORNEYS FOR RESPONDENT: OFFICE OF THE ATTORNEY GENERAL BY: LADONNA C. HOLLAND ALLISON KAY HARTMAN BRAD ALAN SMITH NATURE OF THE CASE: CIVIL - DEATH PENALTY - POST CONVICTION DISPOSITION: LEAVE TO FILE SUCCESSIVE PETITION FOR POST-CONVICTION RELIEF DENIED - 10/13/2022 MOTION FOR REHEARING FILED:

EN BANC.

RANDOLPH, CHIEF JUSTICE, FOR THE COURT:

¶1. Eric Moffett filed a motion for leave to file successive petition for post-conviction

relief (PCR) from his capital murder conviction and sentence of death.

¶2. Moffett was convicted of a savage sexual assault on a five-year-old girl, culminating

in her death. Compelling evidence supported his conviction including, inter alia, conclusive DNA evidence, eyewitness testimony, and a confession. The jury determined that the

victim’s murder was: (1) committed while Moffett was engaged in felonious abuse and/or

battery of a child and (2) especially heinous, atrocious, or cruel. On February 25, 2006, the

jury sentenced Moffett to death.

¶3. Moffett’s conviction and sentence were affirmed by this Court on direct appeal, and

his motion for rehearing was subsequently denied. Moffett v. State, 49 So. 3d 1073 (Miss.

2010). Moffett sought relief in the United States Supreme Court by way of a petition for writ

of certiorari, which was denied on October 3, 2011. Moffett v. Mississippi, 565 U.S. 830,

132 S. Ct. 127, 181 L. Ed. 2d 49 (2011).

¶4. Moffett’s first PCR was primarily encapsulated within ineffective assistance of

counsel claims categorized into three parts: (1) ineffective assistance of André de Gruy and

Dan W. Duggan, Jr., trial counsel; (2) ineffective assistance of de Gruy and Allison R.

Steiner, appellate counsel; and (3) cumulative error. Finding no merit in any of Moffett’s

claims, the Court denied his PCR, as supplemented. Moffett v. State, 156 So. 3d 835 (Miss.

2014), reh’g denied, July 31, 2014.

¶5. Moffett filed a petition for habeas corpus in the United States District Court for the

Southern District of Mississippi, Northern Division, on May 27, 2015.1 Nearly two years

later, on March 17, 2017, Moffett moved for a stay of his federal habeas proceedings to allow

him to exhaust state remedies and raise additional claims he now presents to the Court in his

motion for leave to file successive petition for PCR. More than two years after the case was

1 Moffett v. Hood, No. 3:14 CV639-CWR.

2 pending in the federal court, the federal court granted a stay on September 12, 2017.

¶6. Inexplicably, Moffett delayed nearly four years before filing this motion for leave to

file successive petition for PCR on July 6, 2021. In the instant filing, Moffett raises two

issues. Those claims are subject to three bars. They are untimely and successive. Miss.

Code Ann. §§ 99-39-5(2), -27(9) (Rev. 2020). They are also barred by the doctrine of res

judicata. Miss. Code Ann. 99-39-21(3) (Rev. 2020). Notwithstanding these procedural bars,

the untimely claims lack a substantial showing of the denial of any state or federal right.

Moffett’s motion for leave is denied.

FACTS

¶7. The following factual and procedural background are gleaned from this Court’s

opinion on direct appeal:

Felicia Griffin was sexually abused, [FN1] battered, [FN2] and murdered during the early morning hours of December 31, 1994. Felicia lived in Jackson with her two sisters; mother, Pennie Griffin; and, Pennie’s boyfriend, Moffett. On December 30, 1994, Moffett, Pennie, and the three girls were at home. Moffett left the house at approximately 9:45 p.m. while Pennie was preparing to go to work. Pennie expected Moffett’s mother, Florence Moffett Powell, to arrive soon to take her to work. When Powell did not timely arrive, Pennie went to a nearby gas station to phone her employer and Powell. Pennie checked on the children before leaving, and locked the door and burglar bars as she departed. After going by Pennie’s home, Powell picked up Pennie at the gas station and proceeded to take Pennie to work. It was disputed at trial whether Powell was alone when she arrived at the gas station, or whether she was accompanied by her daughter, Sheritha Moffett. Sheritha testified that she had accompanied Powell and had observed Powell enter the house looking for Pennie. Powell did not testify, as she died before trial. The jury heard evidence that Moffett returned to the house a few hours later, took Felicia into the bedroom he shared with Felicia’s mother, abused Felicia, and savagely raped her with his fingers and fist.

FN1. The perineum had been savagely ripped or torn, resulting in open

3 communication of the excretory opening of the alimentary canal with her genital orifice.

FN2. She had bruises on her neck, face, and left leg; and petechial hemorrhages on her face.

Moffett reported Felicia’s death via a 911 call and awaited the arrival of officers from the Jackson Police Department (JPD). After the police officers arrived, Moffett exhibited anger and began to behave strangely. His behavior escalated to the point that he was “out of control” and “throwing furniture,” according to the testimony of police officers. Four officers subdued Moffett. He was handcuffed and arrested. From his arrest on December 31, 1994, Moffett remained incarcerated until September 7, 1995, when a grand jury returned no true bill. Moffett was released the same day. He had been in custody 250 days.

Years later, a JPD cold-case unit reviewed the file and submitted its findings to the district attorney. Moffett was indicted in April 2002. Moffett was tried, convicted, and received a death sentence in February 2006. Substantial evidence was presented at trial, including the live testimony of numerous witnesses. Witnesses included, but were not limited to, Pennie Griffin; LaQuandia Griffin, the victim’s sister; Donald Davis, a prison inmate; Mary Esther Pearson, a nurse practitioner; Huma Nasir, a forensic DNA analyst for a private DNA laboratory; and Detective Rod Eriksen, a JPD officer.

LaQuandia testified that she was seven years old at the time of the murder. The night of the crime, Pennie helped her and her sisters, Jessica and Felicia, get ready for bed and checked on them before she left for work. The three girls were sleeping on a pallet in a room across the hall from the bedroom shared by Pennie and Moffett. Lights were on in the girls’ bedroom, the hallway, and bathroom. LaQuandia woke up and saw Moffett standing in the doorway of the girls’ bedroom. She saw Moffett pick up Felicia, who was sleeping closest to the door. He took Felicia to his bedroom. He did not close the doors all the way, so she could see him. He placed Felicia down on the bed and started touching and rubbing on her chest and stomach areas. She heard Felicia making “all kind of painful cries.” She then dozed off, only to be awoken later. She saw someone [FN3] in the hallway going into Pennie’s bedroom. She remembered looking into the bedroom and seeing Felicia “laying in the bed and the covers were real bloody.” After the police arrived, Moffett approached her, hugging and attempting to reassure her. She recalled seeing Moffett “throw a fit, . . . he was . . . yelling and screaming, . . . picking

4 up chairs and . . . throwing things as if he cared.” She saw the paramedics take Felicia away on a stretcher.

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