Edwards v. State

Citations: 838 So. 2d 990; 2002 Miss. App. LEXIS 430; 2002 WL 1752836Docket: No. 2001-KA-00858-COA

Court: Court of Appeals of Mississippi; July 30, 2002; Mississippi; State Appellate Court

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Sheron Edwards was convicted of armed robbery and grand larceny by an Oktibbeha County Circuit Court jury, receiving a twenty-year sentence for armed robbery and a five-year sentence for grand larceny, to be served consecutively. Edwards appealed, claiming two errors: the denial of his motion for a directed verdict and the allowance of a defense witness to reference a previous trial involving him. 

On March 13, 1999, Kenneth Burns was robbed at gunpoint by a man who then struck him and fled in Burns's vehicle. Witness Vincent Forside observed a vehicle speeding and losing control, subsequently crashing. Upon arrival, police identified Edwards, who matched the suspect description, and arrested him. Burns identified both Edwards and the stolen vehicle shortly after the robbery. A search of the wrecked car revealed Burns's wallet, and a bullet casing found at the robbery scene matched a firearm found with Edwards at his arrest. Edwards was indicted and found guilty on both charges.

Edwards contended on appeal that the trial court erred by denying his motions for a directed verdict and for judgment notwithstanding the verdict (JNOV), asserting the State did not provide sufficient evidence for his conviction. The legal standard requires that all credible evidence supporting the defendant's guilt be accepted as true, and the prosecution be given all reasonable favorable inferences. The court found that the evidence, including eyewitness testimony from Burns and Forside, as well as possession of the victim's items and the weapon used in the robbery, was adequate to support the jury’s verdict, thus rejecting Edwards's claim.

Additionally, Edwards argued that the trial court incorrectly allowed a witness to reference a previous trial involving him, claiming this was more prejudicial than probative under Mississippi Rules of Evidence 403. He also asserted that his counsel was not permitted to properly object during the trial. However, the record contradicted these claims, showing that the objection was based on a discovery violation. The court determined this issue was procedurally barred because Edwards did not raise the specific grounds for objection on appeal. Furthermore, even considering the merits, the court upheld the trial court's discretion in allowing the evidence, emphasizing that the probative value did not substantially outweigh the potential for unfair prejudice. Thus, the appellate court found no abuse of discretion in the trial court’s ruling.

Cleveland Carlisle's cross-examination revealed significant discrepancies between his testimony in the current state trial and his earlier testimony at a federal trial in Oxford regarding the same matter. The State referenced a prior hearing from August 1999, which Carlisle acknowledged as occurring in Oxford. This prior testimony was used by the State to impeach Carlisle's credibility, although they did not specify that the hearing was part of a federal trial involving Edwards. Edwards contends that the jury might infer he had been tried in federal court based solely on the location. The trial court permitted the use of the federal trial transcript for impeachment, finding it appropriate under M.R.E. 801(d)(1) due to it being a prior inconsistent statement made under oath. Ultimately, the Oktibbeha County Circuit Court's judgment of conviction for armed robbery (twenty-year sentence) and taking a motor vehicle (five-year concurrent sentence) was affirmed, with appeal costs assigned to Oktibbeha County. The decision was concurred by multiple justices.