Victor Washington v. State of Mississippi

CourtCourt of Appeals of Mississippi
DecidedJune 16, 2020
DocketNO. 2018-KA-01142-COA
StatusPublished

This text of Victor Washington v. State of Mississippi (Victor Washington 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
Victor Washington v. State of Mississippi, (Mich. Ct. App. 2020).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2018-KA-01142-COA

VICTOR WASHINGTON APPELLANT

v.

STATE OF MISSISSIPPI APPELLEE

DATE OF JUDGMENT: 01/27/2017 TRIAL JUDGE: HON. LILLIE BLACKMON SANDERS COURT FROM WHICH APPEALED: ADAMS COUNTY CIRCUIT COURT ATTORNEY FOR APPELLANT: OFFICE OF STATE PUBLIC DEFENDER BY: HUNTER NOLAN AIKENS ATTORNEY FOR APPELLEE: OFFICE OF THE ATTORNEY GENERAL BY: LAURA HOGAN TEDDER DISTRICT ATTORNEY: RONNIE LEE HARPER NATURE OF THE CASE: CRIMINAL - FELONY DISPOSITION: AFFIRMED IN PART; REVERSED AND REMANDED IN PART - 06/16/2020 MOTION FOR REHEARING FILED: MANDATE ISSUED:

BEFORE J. WILSON, P.J., GREENLEE AND LAWRENCE, JJ.

GREENLEE, J., FOR THE COURT:

¶1. Victor Washington was convicted by a jury of burglary of a dwelling (Count I),

aggravated assault (Count II), and armed robbery (Count III) in the Adams County Circuit

Court. He was sentenced to serve three concurrent life sentences as a habitual offender under

Mississippi Code Annotated section 99-19-83 (Rev. 2015). Washington now appeals,

claiming that (I) the circuit court erred by failing to instruct the jury on the essential elements

of aggravated assault, (II) his indictment did not allege the essential elements of burglary,

(III) there was insufficient evidence to support his aggravated-assault conviction, and (IV) there was insufficient evidence to support his armed-robbery conviction. We affirm on issues

(II), (III), and (IV), but we reverse and remand for further proceedings consistent with this

opinion as to issue (I), failure to properly instruct the jury.

FACTS AND PROCEDURAL HISTORY

¶2. Around 9:00 p.m. on the night of September 4, 2016, eighty-seven-year-old Kathryn

Hoggatt1 was in her home getting ready for bed when she heard a banging noise on the

carport door. At the door, Hoggatt looked through the window curtain and saw Victor

Washington, a man whom she did not recognize at the time. Washington stated to Hoggatt

that he was there to “haul some stuff” away and that he was Brenda Tuesno’s boyfriend.2

Hoggatt responded to Washington that she did not need his help and turned to walk away.

Washington then broke a glass pane on the carport door and entered the home. Hoggatt

attempted to flee, but Washington was able to grab Hoggatt and force her to the ground. On

the ground, Hoggatt noticed that Washington was carrying a knife. Hoggatt then escaped out

of the carport door as Washington entered her bedroom.

¶3. Terri Burke, Hoggatt’s neighbor, was at her house with her daughter, Kelli Jacobs,

when she heard Hoggatt screaming for help and running toward their home. As Burke

helped Hoggatt inside, Jacobs testified that she noticed blood “all over [Hoggatt’s] arms and

1 The filings and the record are inconsistent in the spelling of Kathryn Hoggatt’s first name. In Washington’s brief, her name is spelled “Kathryn.” In the State’s brief, it is spelled “Katherine.” Other parts of the record use both spellings. We use “Kathryn” herein. 2 Tuesno cleaned Hoggatt’s house.

2 . . . feet.” Jacobs then dialed 911, and Burke called Hoggatt’s daughter.

¶4. Hoggatt was transported to the hospital, where she received a tetanus shot and stitches

in her foot. Investigator Joseph Belling, a crime scene investigator for the Natchez Police

Department (NPD), was dispatched to the hospital. There, he interviewed Hoggatt. During

the interview, Hoggatt exclaimed that she had cut her foot on broken glass. She also stated

that she did not know Washington’s name but that Washington used to drop Tuesno off at

her home. After the interview, Investigator Belling photographed Hoggatt’s injuries and

went to Hoggatt’s residence.

¶5. Other officers had secured the scene by the time Investigator Belling reached

Hoggatt’s residence. At the scene, Investigator Belling noticed drops of blood and shattered

glass scattered across the kitchen floor. He also saw blood inside Hoggatt’s bedroom,

specifically on and around Hoggatt’s bedroom dresser. Investigator Belling collected some

of the blood-stained evidence, including a piece of Hoggatt’s carport door and a tank top that

he found inside the dresser. He also took several swabs of blood. The items were sent to the

Mississippi Forensics Laboratory for testing. After searching the scene, Investigator Belling

returned to the hospital to take Hoggatt’s DNA sample.

¶6. With Hoggatt’s disclosures and help from other officers, Investigator Belling

developed Victor Washington as the primary suspect. On September 6, 2016, Investigator

Belling presented Hoggatt a photo lineup using driver’s license photos. After viewing

Investigator Belling’s lineup, Hoggatt narrowed the pretrial identification down to two

3 pictures but refused to conclusively answer because of the lack of clarity in the driver’s

license photos. The next day, Investigator Belling compiled a second photo lineup using

booking photographs. Hoggatt then identified Washington. After Hoggatt identified

Washington, Lieutenant Kenneth Stamply made the arrest. At the jail, Washington’s DNA

was taken.

¶7. Washington was subsequently indicted by a grand jury of burglary of a dwelling

(Count I), aggravated assault (Count II), and armed robbery (Count III). The case was tried

on January 25-26, 2017. The State presented nine witnesses. One of those witnesses was

William Jones, a supervisor at the Mississippi Forensics Laboratory, who was received as an

expert in the field of DNA analysis. Jones testified that the blood stains on Hoggatt’s tank

top were consistent with Washington’s DNA profile. Following the State’s case-in-chief,

Washington moved for a directed verdict on Counts II and III. Both motions were denied.

Washington then testified in his defense.

¶8. According to Washington, Tuesno asked him if he would help her break into

Hoggatt’s home and steal money. Washington testified that he had planned to “break the

door” while Tuesno entered the home to “get the money.” Washington then admitted that

he broke Hoggatt’s door on the night in question. Washington also testified that he cut his

arm while breaking glass on the carport door. Washington denied entering Hoggatt’s home.

He also denied having a knife.

¶9. At the end of trial, the jury found Washington guilty on all three counts. Washington

4 was sentenced as a habitual offender under Mississippi Code Annotated section 99-19-83 to

three concurrent life sentences to be served in the Mississippi Department of Corrections.

Washington now appeals his convictions and sentences.

DISCUSSION

¶10. Washington raises the following issues on appeal: (I) the circuit court erred by failing

to instruct the jury on the essential elements of aggravated assault, (II) his indictment did not

allege the essential elements of burglary, (III) there was insufficient evidence to support his

aggravated-assault conviction, and (IV) there was insufficient evidence to support his armed-

robbery conviction. We address these issues below, combining the last two issues for

purposes of this discussion.

I. Whether the circuit court erred by failing to instruct the jury on the essential elements of aggravated assault.

¶11. Washington argues that the circuit court erred by failing to instruct the jury on the

essential elements of aggravated assault (Count II). In particular, he claims that the jury was

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