Renfro v. State

Citations: 118 So. 3d 560; 2013 WL 1459466; 2013 Miss. LEXIS 150Docket: No. 2012-KA-00643-SCT

Court: Mississippi Supreme Court; April 11, 2013; Mississippi; State Supreme Court

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David Javarious Jamison "Jamie" Renfro was convicted of armed robbery under Mississippi Code Section 97-3-79 by the Circuit Court of Lincoln County. The robbery occurred on March 21, 2011, when Renfro entered Andra Roundtree's trailer home, brandishing a gun and demanding money. Roundtree and another eyewitness, Jeremy McCollum, provided testimony supporting the prosecution's case, while a third potential eyewitness, Tonia Daniels, was unable to testify at trial. Renfro did not testify in his defense.

During the incident, Renfro threatened Roundtree, held a gun to his head, and demanded valuables. He took Roundtree's backpack and a .380 caliber handgun before fleeing the scene. Following the robbery, a neighbor called the police, and Officer Fred Perkins arrived shortly after. He found Roundtree visibly shaken and nervous but noted that there were no signs of struggle or physical evidence at the scene. Key items, including the weapons and backpack, were never recovered. 

On appeal, Renfro argued that the jury's verdict was against the overwhelming weight of the evidence; however, the court upheld the conviction, finding the evidence sufficiently supported the jury's decision. Renfro was sentenced to twenty years in prison, with five years suspended.

Roundtree provided a statement identifying David James Renfro (alias Jamie) as the individual who threatened him with a gun during a robbery at his home. In his trial testimony, Roundtree clarified that he initially knew Renfro only as "Jamie" and learned his full name from Renfro’s father. Officer Perkins corroborated that Renfro’s first name was David. Roundtree described his statement as hurried, completing it in under ten minutes, and noted that certain details were omitted, including the presence of another individual named Jay. He anticipated further questioning by police, which did not occur until trial.

Roundtree was the sole witness attesting to Renfro’s possession of a gun and the theft of his property. He had known Renfro for four years, having lived next door previously, and mentioned that he stored rent money at home. Roundtree, who suffers from paranoid schizophrenia and had been in therapy, was not on medication at the time of the robbery but later began treatment.

Jeremy McCollum, another witness, testified that he was unsure if Renfro had a gun during the incident, admitting he was too frightened to confirm the object in Renfro's hand and did not see a gun.

Additionally, it was revealed that Roundtree shot and injured someone shortly after filing his police statement, leading to an indictment for aggravated assault. However, this information was not presented to the jury due to his Fifth Amendment rights. Ultimately, the jury found Renfro guilty but did not recommend life imprisonment. The trial court denied his request for a new trial, and Renfro was sentenced to twenty years in prison with five years suspended. His appeal centers on whether the trial court erred in denying the new trial based on the evidence's weight.

Renfro contends that the trial testimony was unreliable and inconclusive, suggesting that police investigations were minimal and that Roundtree provided incomplete or misleading statements. He highlights a contradiction between Roundtree’s and McCollum’s testimonies, particularly noting McCollum's claim of not seeing a gun. Additionally, Renfro points out Roundtree's paranoid schizophrenia, arguing that the jury could not fully evaluate Roundtree's credibility due to the lack of evidence regarding Roundtree's indictment for a gun-related incident involving Renfro that occurred the day after the robbery. The State defends the conviction, asserting substantial evidence supported the jury’s decision.

Regarding the legal standards for overturning a trial court's denial of a new trial, it is established that such a denial will be reversed only if the court abused its discretion. A new trial may be warranted only when the verdict is significantly contrary to the evidence, with courts favoring the jury's findings unless exceptional circumstances arise where the evidence heavily contradicts the verdict. Even if the evidence seems to support a new trial, Renfro's only recourse would be a new trial rather than an acquittal.

Precedents indicate that verdicts may be overturned if based on weak evidence, but the assessment of witness credibility lies solely with the jury. The jury is tasked with evaluating evidence's weight and credibility and may make reasonable inferences based on their experiences. Renfro was convicted of armed robbery, defined under Mississippi law as unlawfully taking or attempting to take another's property through violence or intimidation, requiring the jury to determine whether Renfro took property from Roundtree and whether he instilled fear of immediate injury in Roundtree by displaying a weapon.

The jury found that Renfro took or attempted to take Roundtree’s personal property based on the testimony of a single witness, Andra Roundtree, who claimed Renfro stole his gun and backpack. Although the items were never recovered, no witnesses contradicted Roundtree’s assertion of theft. McCollum, who left before the theft, confirmed Renfro's presence and demands for Roundtree and Daniels to get on the floor, allowing the jury to infer an attempt to rob. The jury was justified in believing Roundtree, despite his diagnosis of paranoid schizophrenia, as his claims were credible and consistent with his role as a rent collector with cash. 

Regarding the second question, the jury found that Renfro placed Roundtree in fear of immediate injury by exhibiting a deadly weapon. Testimonies from Roundtree and McCollum supported this, with Roundtree stating Renfro placed a gun to his head and pointed it visibly at him, while McCollum observed Renfro making frightening demands. Although McCollum did not see the gun, his fear was evident, leading the jury to reasonably conclude that the object was a weapon. Officer Perkins noted Roundtree's distressed state shortly after the incident, which the jury could interpret as indicative of someone who had just experienced a traumatic event involving a firearm. Overall, the jury's findings were supported by sufficient evidence.

The testimony of a single uncorroborated witness can support a conviction, as established in Williams v. State. In this case, Roundtree's eyewitness account was not directly contradicted, and his statements were largely corroborated by McCollum, aside from McCollum’s uncertainty regarding whether Renfro had a gun. Such inconsistencies do not necessitate rejecting a witness's entire testimony, as noted in Duncan v. State. The jury could reasonably believe that Renfro used a gun to instill fear in Roundtree and committed theft.

Renfro contended that the jury lacked complete information due to Roundtree's Fifth Amendment right against self-incrimination, which prevented cross-examination about Roundtree’s aggravated assault indictment. He argued this would have impeached Roundtree's credibility. However, Renfro acknowledged that his Sixth Amendment right to cross-examine must yield to Roundtree’s Fifth Amendment privilege. The court correctly excluded this evidence, as supported by United States v. Hernandez.

Even if the jury had heard the excluded evidence, it would not have overwhelmingly contradicted the verdict, as it does not negate Roundtree’s testimony. Instead, it could indicate Roundtree's potential motive to lie due to anger over being robbed by Renfro. The court emphasized that the evidence against Renfro was not weak or doubtful, and the jury's decision was not an unconscionable injustice. The circuit court's denial of Renfro's motion for a new trial was within its discretion.

The conviction for armed robbery was affirmed, with a sentence of 20 years in custody, including five years suspended, and 15 years to serve. Renfro is also ordered to pay court costs, a fine, and restitution.