JaTryan Martel Tuggle a/k/a JaTyran Tuggle a/k/a Jaytran Tuggle v. State of Mississippi

CourtCourt of Appeals of Mississippi
DecidedFebruary 27, 2024
Docket2022-KA-00118-COA
StatusPublished

This text of JaTryan Martel Tuggle a/k/a JaTyran Tuggle a/k/a Jaytran Tuggle v. State of Mississippi (JaTryan Martel Tuggle a/k/a JaTyran Tuggle a/k/a Jaytran Tuggle 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
JaTryan Martel Tuggle a/k/a JaTyran Tuggle a/k/a Jaytran Tuggle v. State of Mississippi, (Mich. Ct. App. 2024).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2022-KA-00118-COA

JATRYAN MARTEL TUGGLE A/K/A JATYRAN APPELLANT TUGGLE A/K/A JAYTRAN TUGGLE

v.

STATE OF MISSISSIPPI APPELLEE

DATE OF JUDGMENT: 12/08/2021 TRIAL JUDGE: HON. ROBERT B. HELFRICH COURT FROM WHICH APPEALED: FORREST COUNTY CIRCUIT COURT ATTORNEY FOR APPELLANT: BRANDON ISAAC DORSEY ATTORNEY FOR APPELLEE: OFFICE OF THE ATTORNEY GENERAL BY: ASHLEY LAUREN SULSER DISTRICT ATTORNEY: PATRICIA A. THOMAS BURCHELL NATURE OF THE CASE: CRIMINAL - FELONY DISPOSITION: AFFIRMED IN PART; REMANDED IN PART - 02/27/2024 MOTION FOR REHEARING FILED:

BEFORE CARLTON, P.J., WESTBROOKS AND EMFINGER, JJ.

EMFINGER, J., FOR THE COURT:

¶1. JaTryan Tuggle was tried and convicted of capital murder and conspiracy to commit

armed robbery in the Forrest County Circuit Court. He was sentenced to serve a term of life

imprisonment in the custody of the Mississippi Department of Corrections (MDOC) without

eligibility for parole for this life sentence. He was also sentenced to serve twenty years1 in

1 The trial judge amended Tuggle’s sentence for conspiracy to commit armed robbery on the record at the conclusion of the hearing on Tuggle’s post-trial motion on December 22, 2021. The trial judge reduced the sentence from twenty years to five years (the statutory maximum sentence). However, no written order reflecting this amendment is contained in the record on appeal. MDOC’s custody for conspiracy to commit armed robbery, which was ordered to run

consecutively to the life sentence.

FACTS AND PROCEDURAL HISTORY

¶2. On July 20, 2019, Tuggle drove his black Dodge Avenger from Jackson to

Hattiesburg, Mississippi, with three passengers: Christopher Tyce, Eric Williams, and

Stephon Hart. After arriving in Hattiesburg, the four men stopped at Steelman Grocery.

Tyce, Williams, and Hart entered the store carrying guns and wearing face coverings while

Tuggle remained outside in his vehicle, which was still running. While in the store, Tyce

fired multiple shots which resulted in the death of the store’s co-owner, Lisa Nguyen.

Williams jumped over the counter and grabbed the cash register while Hart stood at the door

as the lookout. After they robbed the store, Tyce, Williams, and Hart jumped back in

Tuggle’s vehicle and he drove them back to Jackson.

¶3. On September 8, 2020, a Forrest County Grand Jury returned a four-count indictment

against multiple defendants in which Tuggle was charged in Count I with capital murder

pursuant to Mississippi Code Annotated section 97-3-19(2)(e) (Supp. 2017) and in Count IV

with conspiracy to commit armed robbery pursuant to Mississippi Code Annotated section

97-1-1 (Rev. 2014) and 97-3-79 (Rev. 2014).2 After a three-day trial, a jury found Tuggle

guilty of both Count I and Count IV of the indictment. A sentencing order was signed on

November 17, 2021. On December 1, 2021, Tuggle filed a “Motion for Judgment

2 Tuggle was jointly indicted with Tyce, Williams, and Hart. All four defendants were charged in Counts I and IV, and only Tyce was charged in Counts II and III. While there is no order in the record on appeal, the transcript reveals that the defendants’ cases were severed and tried separately.

2 Notwithstanding the Verdict or in the Alternative a New Trial and For a Reasonable Bail

Pending Appeal and Other Relief.” Although a written order was never entered, the trial

court denied Tuggle’s motion in open court on December 22, 2021, and Tuggle filed his

notice of appeal.

ANALYSIS

¶4. Tuggle essentially raises three assignments of error on appeal. First, he argues that

the trial court erred by permitting the Forrest County Deputy Coroner Lisa Klem to testify

“as to the manner and cause of [Nguyen’s] death.” Secondly, he contends that the trial court

erred by admitting Exhibit S-106 at trial. Third, he argues that the trial court erred by

denying his motion for a directed verdict or JNOV because that the State allegedly presented

insufficient evidence to convict him of capital murder and conspiracy to commit armed

robbery.3

I. Did the trial court err by permitting Forrest County, Mississippi Deputy Coroner Lisa Klem to testify as to the manner and cause of Nguyen’s death?

¶5. Because Klem is not a pathologist and did not perform an autopsy on Nguyen, Tuggle

maintains that Klem was not qualified to offer any testimony as to the cause and manner of

Nguyen’s death. He further argues that his Sixth Amendment right to confront the witnesses

against him was somehow violated by allowing Klem to testify to the cause and manner of

death. As will be discussed below, Klem conducted her own investigation and formed her

own opinions that were given in court, subject to cross-examination. No autopsy report was

3 The third and fourth arguments Tuggle asserts on appeal are consolidated for the purpose of analysis in this opinion in Part III.

3 offered into evidence.

¶6. This Court addressed a similar issue in Parks v. State, 235 So. 3d 111, 117-18 (¶¶21-

23) (Miss. Ct. App. 2017), and found as follows:

We begin by emphasizing that although it is the State’s burden to prove that “death resulted from a criminal agency,” “[i]t is well established . . . that proof of the cause of death in homicide cases may be by lay testimony.” Neal v. State, 386 So. 2d 718, 719-20 (Miss. 1980). As our Supreme Court has explained, “[t]he criminal agency or cause of death is usually shown by witnesses who saw the homicide, or by circumstances sufficient to establish the crime to the exclusion of every other reasonable hypothesis.” Gibson v. State, 503 So. 2d 230, 233 (Miss. 1987) (quoting King v. State, 251 Miss. 161, 176, 168 So. 2d 637, 643 (1964)). In such cases, neither an autopsy nor expert medical opinion is necessary. Id. The evidence concerning the circumstances of the death in this case was, like many homicide cases, sufficient to establish the cause of death without expert testimony. Parks admitted that he shot Tarver, and Tarver was found dead at the scene with significant blood loss from obvious bullet wounds in his arm and torso.

Nonetheless, Parks timely objected to Evans’s testimony concerning the manner and cause of death. Evans was appointed deputy medical examiner by the county coroner. She is not a medical doctor but has an associate’s degree in medical laboratory technology, has completed forty hours of training in basic death investigation, and is required to complete twenty-four hours of continuing education each year. Parks argues that her opinion as to the manner and cause of death was improper expert testimony that should have been excluded under Rule 702 and Daubert v. Merrell Dow Pharmaceuticals Inc., 509 U.S. 579 (1993), which our Supreme Court adopted in Mississippi Transportation Commission v. McLemore, 863 So. 2d 31 (Miss. 2003). In response, both during trial and on appeal, the State has agreed that Evans was not tendered or qualified as an expert. Thus, the issue really boils down to whether Evans’s testimony was permissible lay opinion testimony. See M.R.E. 701; Jones v. State, 678 So. 2d 707, 710 (Miss. 1996).

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JaTryan Martel Tuggle a/k/a JaTyran Tuggle a/k/a Jaytran Tuggle v. State of Mississippi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jatryan-martel-tuggle-aka-jatyran-tuggle-aka-jaytran-tuggle-v-state-of-missctapp-2024.