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Shields v. State
Citations: 920 So. 2d 1033; 2005 Miss. App. LEXIS 779; 2005 WL 2739811Docket: No. 2004-KA-00631-COA
Court: Court of Appeals of Mississippi; October 25, 2005; Mississippi; State Appellate Court
Mary Shields was convicted of murder and sentenced to life imprisonment, appealing on the grounds that the trial court erred in denying her motion for a new trial, arguing that the guilty verdict was against the weight and sufficiency of the evidence. Shields contends that while the State proved the elements of manslaughter, it failed to establish intent to kill or evidence of a "depraved heart." The court affirmed her conviction and sentence.
The incident occurred on New Year’s Eve 2002-03 at Club Elite in Columbus, Mississippi, where Shields was with her son Joseph and a friend, Mary Moore ("St. Louis"). St. Louis was intoxicated and required assistance from Shields. A confrontation arose between Shields and Larry Martin, who was also intoxicated and had a prior relationship with St. Louis, leading to a physical altercation involving all parties.
Witnesses provided varying accounts of the melee, which lasted approximately 15-20 minutes. Brenda Lowery observed Shields and Joseph attacking Martin, with Joseph kicking him and Shields swinging a barstool. Lowery testified that Martin was unable to defend himself during this time. Other witnesses corroborated that Shields was actively involved in the fight and did not attempt to stop despite efforts from bystanders.
After the fight, Martin was hospitalized and subsequently died. Shields claimed that Martin died from a heart attack and that blunt force trauma was not the cause of death. However, the State's expert testimony indicated that the immediate cause of death was blunt force trauma, although Martin's pre-existing heart condition was noted as a complicating factor.
Dr. Steven Hayne, the State's pathologist, testified that Larry Martin's immediate cause of death was blunt force trauma, while the underlying causes included preexisting cardiovascular conditions such as hypertensive heart disease and coronary artery disease. Dr. Hayne clarified that the blunt force trauma did not directly cause death but could be lethal in individuals with existing heart disease. He noted that Martin's heart condition, typical for his age, was not lethal on its own and that there was no evidence of a heart attack.
Mary Shields was indicted for deliberate design murder and tried in Lowndes County. After the State's case-in-chief, the defense motioned for a directed verdict on the murder charge, suggesting a manslaughter charge instead, but this was denied. Shields did not testify, and her witnesses did not significantly challenge the State's evidence. The jury convicted her of murder, leading to a life sentence. The defense's subsequent motions for a judgment notwithstanding the verdict or a new trial were denied.
The appellate issue centers on whether Shields's conviction was against the weight and sufficiency of the evidence. The court stated it would only reverse a verdict if it contradicted the overwhelming weight of the evidence, requiring a view of the evidence favoring the verdict. The distinction between evaluating the weight of evidence and its legal sufficiency was made, emphasizing that a conviction must be supported by evidence beyond a reasonable doubt. Shields argued that Martin's death was due to a heart attack and "heat of passion," but the pathologist's testimony refuted this claim, as no evidence supported a heart attack.
Shields references Dedeaux v. State, 630 So.2d 30 (Miss.1993), to argue similarity with her case, but the circumstances differ significantly. In Dedeaux, the shooting occurred during a confrontation where evidence indicated self-defense, leading to a manslaughter verdict. In contrast, Shields engaged in a prolonged assault on Martin, evidenced by testimony of Martin's defensive posture as Shields struck him with sufficient force to break a barstool, indicating no self-defense on her part.
Shields also cites Clemons v. State, 473 So.2d 943 (Miss.1985), involving a barroom brawl with conflicting testimonies that created reasonable doubt about murder. However, in Shields' case, there was clear evidence of her aggressive behavior toward Martin with no significant dispute over the facts.
Both Dedeaux and Clemons reference Wells v. State, 305 So.2d 333 (Miss.1974), which involved a sudden fight with no witnesses. In contrast, numerous eyewitnesses observed Shields' extended altercation with Martin, lasting up to twenty minutes, during which she was the aggressor.
After reviewing the evidence favorably to the verdict, it is concluded that the evidence against Shields is substantial and consistent with a murder conviction. Her actions, repeatedly hitting Martin with a barstool, indicate a deliberate design to kill. The court affirms the conviction of murder and the life sentence imposed by the Circuit Court of Lowndes County, with all appeal costs assessed to Lowndes County.