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Crawford v. State
Citations: 66 So. 3d 1284; 2011 Miss. App. LEXIS 456; 2011 WL 3066637Docket: No. 2009-KA-01905-COA
Court: Court of Appeals of Mississippi; July 26, 2011; Mississippi; State Appellate Court
Letarius Crawford was convicted of murder and aggravated assault in the Washington County Circuit Court and sentenced to life imprisonment for murder and twenty years for aggravated assault. Crawford appealed, arguing that the court erred by not allowing a manslaughter instruction. The court affirmed the conviction, finding no reversible error. On August 29, 2008, Crawford shot Lashaunda Lewis in a hotel room at the Express Inn in Greenville, Mississippi. Lewis had previously been in a romantic relationship with Crawford and had brought her cousin, Dareyn Myrick, to the hotel for safety. Myrick testified that after Lewis entered Room 245, he heard her scream and gunshots. Crawford then exited the room and shot at Myrick, hitting him three times before Myrick escaped to the lobby. When police arrived, they found Lewis dead in the room, having suffered four gunshot wounds. Evidence collected included bullets, cigarette butts, beer bottles, and a gun holster. Dr. Feng Li, who conducted the autopsy, confirmed that Lewis's death was a homicide, with wounds indicating she was shot from above, among other injuries. Robert Esters, a witness, saw Lewis arrive at the hotel and heard gunshots shortly after she entered the room, later observing Crawford exit and fire into her truck. Eugina Allen testified about a July 4, 2008, incident involving her brother Lewis and Crawford, who repeatedly called Lewis during a family gathering, leaving threatening voicemail messages. Allen recounted that Crawford screamed for Lewis's whereabouts and threatened to kill him. She also mentioned a prior phone conversation regarding Crawford's physical abuse of Lewis, which she estimated occurred in June 2008. During cross-examination, Allen acknowledged the violent nature of Lewis and Crawford's relationship. Crawford provided a recorded statement to law enforcement after the shooting, played for the jury. In it, he claimed that Lewis informed him the day before the shooting that she had given him AIDS, which he believed devastated his life. Crawford admitted he had not been tested for the disease prior to confronting Lewis and recalled shooting her but could not explain his motive; he also had no memory of shooting Myrick. The legal analysis section references case law regarding jury instructions, emphasizing the trial court's discretion in granting them. A defendant is entitled to instructions that align with their theory if evidence supports it, but instructions can be denied if they misstate the law, are redundant, or lack evidentiary support. The appellate court evaluates jury instructions as a whole to determine if they adequately represent the law without causing injustice. Regarding manslaughter, a defendant can only receive a jury instruction if factual grounds are established. Heat-of-passion manslaughter requires evidence of uncontrollable rage triggered by provocation, which can reduce a homicide charge from murder to manslaughter. The provocation must be immediate and reasonable, capable of inciting extreme emotional responses in an ordinarily constituted person. Crawford's request for a manslaughter instruction was denied as it lacked evidentiary support. His argument that an incident at the hotel provoked him to shoot Lewis was unsubstantiated. Crawford admitted to being angry about an alleged AIDS infection from Lewis but did not recall the reason for the shooting. Testimony indicated he was not in an excited state during the shooting and chose to stop pursuing another victim, Myrick, once he reached safety. The only potential provocations were the AIDS allegation and seeing Lewis, neither of which occurred at the time of the shooting. The court emphasized that provocation must elicit immediate passion or anger, which was not demonstrated in this case. Consequently, the circuit court's ruling that there was insufficient provocation to warrant a manslaughter instruction was upheld. The judgment of conviction for murder and aggravated assault, along with the respective sentences, was affirmed, with all appeal costs attributed to Washington County.