Clint Baldwin was convicted of capital murder in the Lowndes County Circuit Court and sentenced to life imprisonment. The case involved the kidnapping, rape, and murder of thirty-year-old Mary Elizabeth Mosley Dill, reported missing by her husband, Bryan Dill, on April 6, 1996. After a brief investigation, her mutilated body was discovered on April 9, 1996. Initial investigations revealed no signs of forced entry or struggle at the Dill residence, although a .25 caliber handgun was reported missing.
Investigators later focused on Clint and Darnell Baldwin after learning they had attended a party at the Dill residence on the night of Liz's disappearance. Witnesses noted their presence and interactions with Bryan Dill during the party. Darnell Baldwin's behavior during police interviews raised suspicion, particularly his refusal to cooperate and the subsequent disappearance of his car, which was later found burned in Alabama.
An autopsy by Dr. Steven Hayne determined that Liz died from a gunshot wound to the back of her head, inflicted by a high-velocity bullet. Evidence of defensive wounds indicated she had attempted to protect herself prior to her death, and her skin had been removed from significant parts of her body post-mortem. The case was eventually affirmed by the Supreme Court of Mississippi on April 12, 2001, following Baldwin's appeal.
Dr. Hayne collected seminal fluid from the victim, Liz, and a blood sample from Darnell Baldwin for DNA testing at GenTest (now Reliagene Technologies). Expert Anne Montgomery testified that the DNA from the seminal fluid matched Darnell’s blood. In July 1996, Stanley Abrams, a friend of Clint Baldwin, provided a statement after his arrest for witness intimidation, claiming Clint confessed to him about Liz's murder. The statement detailed how Clint and Darnell, following instructions from Bryan Dill, attacked Liz at her home, with Clint using a gun and a machete, while Darnell raped her. They subsequently killed Liz and disposed of her body in a gravel pit, where deputies later found evidence.
In September 1996, both Clint and Darnell were arrested for capital murder. Darnell was convicted and sentenced to life without parole, a decision upheld by the court. While awaiting trial, Clint discussed the murder with fellow inmate Michael Ball, admitting they were hired to dispose of a body but ended up killing Liz when they found her alive. Clint was later tried and sentenced to life imprisonment. He is now appealing, arguing that the trial court erred by not quashing the venire due to the lower percentage of black citizens in Jackson County compared to Lowndes County, claiming this violated his right to a fair and impartial jury.
A defendant is not entitled to a change of venue to a county with a similar percentage of black citizens as the original venue, as established in Simon v. State, 688 So. 2d 791 (Miss. 1997). In Simon's case, he was moved from Quitman County, where 53.6% of registered voters were black, to Jones County, with 21% black voters, and subsequently to DeSoto County, where 15.2% were black. On appeal, Simon argued that moving to DeSoto County constituted error because it had fewer black citizens than Quitman County. The court clarified that while defendants have the right to a jury selected through nondiscriminatory criteria, the Sixth Amendment does not require juries to mirror the community’s demographics. Simon failed to provide legal support for his claim of entitlement to a venue change with a similar population composition. The court also affirmed that the trial judge has discretion over venue changes in criminal cases, ruling that Baldwin did not demonstrate any abuse of that discretion.
Baldwin claimed that the State unconstitutionally used peremptory challenges to exclude black jurors, referencing Batson v. Kentucky. The State countered that it provided race-neutral reasons for its actions, having used eight out of twelve peremptory strikes against black jurors.
To establish a prima facie case of racial discrimination in peremptory challenges, a defendant must demonstrate membership in a cognizable racial group and show that the prosecutor used peremptory challenges to exclude jurors of that race. The defendant may rely on the accepted understanding that peremptory challenges allow for potential discrimination. Furthermore, the defendant must provide evidence suggesting that the prosecutor's actions were racially motivated. Under Batson, the objecting party must initially present a prima facie case of racial discrimination, after which the burden shifts to the party who exercised the challenge to provide a race-neutral justification. The trial court then evaluates whether purposeful discrimination occurred. The standard for reviewing Batson claims grants significant deference to trial judges’ factual findings, with appellate courts reversing only if those findings are clearly erroneous.
In specific instances, the State cited various race-neutral reasons for its peremptory challenges against black jurors, including a juror's profession, body language, and demeanor, as well as concerns about living in a high-crime area or having prior arrests. For example, a black social worker was struck due to her profession and demeanor, while a black male juror was excluded for his surname and neighborhood. Other jurors were challenged based on their views on the death penalty, prior arrests, and perceived credibility issues.
Guidance for trial courts was provided in Lockett, approving a list of race-neutral reasons for juror challenges, including living in high-crime areas, body language, demeanor, distrust of the juror, inconsistencies in responses, and criminal history. Each reason presented by the State in this case aligns with the Lockett list, which is not exhaustive. The defense, prosecution, and trial court adhered to the Batson procedure, with the trial court correctly determining that the State's reasons were facially race-neutral, rendering the defense's assignment of error meritless.
At trial, a DNA expert testified that seminal fluid from the victim matched the DNA of Darnell Baldwin, which the defense argued was more prejudicial than probative. The State contended that this evidence was relevant to its theory that Clint and Darnell Baldwin kidnapped and murdered Liz Dill, supporting the assertion of Darnell's involvement in her rape. Under Mississippi Rule of Evidence 401, relevant evidence may be excluded if its prejudicial value outweighs its probative value per Rule 403. The appellate court noted it does not re-evaluate the Rule 403 balancing but checks for abuse of discretion by the trial court.
The evidence of Darnell's seminal fluid being found in the victim is relevant, as it supports the State's theory and corroborates testimonies regarding Clint's admissions about Darnell's actions during the crime. The court found no abuse of discretion by the trial court in admitting this evidence. Lastly, the document addresses whether the trial court erred in admitting evidence related to Stanley Abrams' arrest for witness intimidation, though this specific issue requires further examination.
Baldwin argues that the trial court incorrectly permitted the State to introduce evidence regarding Stanley Abrams' arrest for witness intimidation, asserting that this evidence pertained to Abrams' "bad character" rather than his credibility. The State counters that Baldwin mischaracterized the evidence allowed by the court. During cross-examination, Abrams confirmed his arrest occurred when he provided a statement to investigators, prompting Baldwin's objection, which was sustained by the court. Despite the objection, defense counsel sought a mistrial, which the court denied after instructing the jury to disregard the improper testimony. The court maintained that jurors are presumed to follow such instructions, referencing precedent that supports the view that sustaining an objection and admonishing the jury prevents prejudicial error. Thus, the trial court did not err in its handling of the evidence regarding Abrams' arrest.
Additionally, the trial court admitted five photographs of Liz Dill's body, despite defense objections that they were excessively prejudicial. The court acknowledged the gruesomeness of the images but deemed them relevant for illustrating the severity of Dill's injuries. Baldwin contends the photographs lacked evidentiary value and were inflammatory, while the State argues that they effectively demonstrated the condition of Dill’s body and the nature of her wounds.
Admissibility of photographs is at the trial court's discretion, upheld on appeal unless there is an abuse of that discretion (Taylor v. State). Appellate courts do not re-examine the Rule 403 balancing test but assess whether the trial court misused its discretion in admitting or excluding evidence. Photographs are considered evidentiary when they clarify the circumstances surrounding a crime, including the location of a body and cause of death, and may support witness testimony, provided they are not excessively gruesome (Westbrook v. State). Only one instance of inadmissibility due to excessive gruesomeness was noted, involving a decomposed skull (McNeal v. State). In the current case, the admitted photographs illustrated the body's position and wounds, corroborating forensic testimony about the condition of the victim's body. The trial court permitted only eight out of approximately one hundred photographs, determining that their probative value outweighed any prejudicial impact, which was not considered an abuse of discretion.
Additionally, an objection was raised regarding hearsay testimony from Bryan Dill about the life insurance on his wife. Detective Tony Mulligan testified about Bryan's statement indicating he had approximately $12,000 to $25,000 in life insurance, but later evidence revealed the amount was over $250,000. Baldwin only objected to the first insurance amount, not the latter, which does not challenge the admissibility of the second figure.
Bryan Dill's statement regarding life insurance was presented by the State not to prove its truth but to illustrate his misleading behavior towards the detective, supporting the theory that he hired Clint and Darnell Baldwin to kill his wife for financial gain. The State argued that Dill's motive was evident in his attempt to conceal the truth. Hearsay, as defined by Miss. R. Evid. 801(c), refers to statements offered to prove the truth of the matter asserted, whereas those not offered for that purpose are admissible if they meet other evidentiary standards. In this case, Detective Mulligan's testimony was not considered hearsay, as it did not aim to establish the specifics of Dill's life insurance policy.
The State also introduced evidence of a pair of black shorts and a .270 caliber rifle casing found at a gravel pit linked to Stanley Abrams. Baldwin challenged this evidence's relevance and its connection to him, arguing it was more prejudicial than probative. The State defended its relevance by connecting it to Abrams' statements and the medical examiner's testimony that a .270 caliber could inflict a fatal wound. Relevant evidence is defined under Miss. R. Evid. 401, but can be excluded under Rule 403 if its prejudicial impact outweighs its probative value. The admission of the shorts was supported by Clint Baldwin's prior admission regarding Liz Dill's clothing, while the rifle casing corroborated the cause of death as testified by Dr. Hayne. The jury was tasked with resolving any conflicts in the presented evidence, as determined by established case law.
The evidence of the shorts and rifle shell casing supports the State's theory that Clint and Darnell Baldwin abducted, raped, and murdered Liz Dill, qualifying as relevant under Rule 401. The trial court's admission of this evidence was justified as its probative value was not outweighed by any prejudicial factors listed in Rule 403, indicating no abuse of discretion.
Regarding the admission of evidence related to Darnell Baldwin's burned 1975 Monte Carlo, the court found it significantly probative as the vehicle was used to transport Liz Dill. Witness testimonies linked the car to critical events, including its presence at the crime scene and Darnell's refusal to allow examination of it. Despite claims of prejudice, the court applied Rule 403 and determined the evidence's relevance outweighed any potential unfair prejudice, thus affirming no abuse of discretion.
Lastly, the court allowed testimony from Cindy Hosli regarding threats made by Clint Baldwin, which indicated his guilty knowledge. The trial court ruled that the probative value of this testimony outweighed any potential prejudice, supporting the decision to admit it.
Cindy Hosli testified outside the jury's presence regarding her interaction with Deputy Marc Miley about Liz Dill's murder in late June or early July 1996. After this conversation, Clint Baldwin approached her at her workplace, expressing concern that she and a co-worker were speaking to the police. He made an intimidating remark by running his fingers through the co-worker's hair and suggesting he could harm her. Hosli clarified that she had no knowledge of the murder and could not assist Deputy Miley.
Baldwin sought to exclude Hosli's testimony, arguing it was more prejudicial than probative. However, the trial court deemed the testimony relevant, indicating it suggested Baldwin's consciousness of guilt. The court allowed the testimony after weighing its probative value against potential unfair prejudice, and provided a limiting instruction to the jury.
Referencing the Fifth Circuit's decision in United States v. Bright, where witness intimidation was deemed relevant to show consciousness of guilt, the trial court's ruling was affirmed. The court concluded that Hosli's testimony was neither cumulative nor misleading, and the only delay was related to its admissibility deliberation. The trial court did not abuse its discretion under Rule 403 in admitting the testimony.
The assignment of error concerning the trial court's decision to allow the State to impeach defense witness Terry Dora with his cocaine sale conviction is deemed without merit. Baldwin contends that the trial court failed to adequately assess the admissibility of Dora's conviction. The State argues that this evidence was necessary to demonstrate Dora's bias against the prosecuting district attorney. Dora, who was Baldwin's cellmate, testified that Baldwin had not discussed the charges against him, contradicting State's witness Michael Ball's claim that Baldwin had discussed a murder case. Before cross-examination, the assistant district attorney informed the judge of his intention to use Dora's conviction to highlight potential bias, which the court permitted.
According to Rule 609 of the Mississippi Rules of Evidence, evidence of a witness's prior conviction can be admitted to challenge credibility if the crime is punishable by over a year of imprisonment or involves dishonesty. The trial judge must determine that the probative value outweighs the prejudicial effect before admission. The court referenced factors from prior cases that should guide this determination, such as the nature of the crime, timing of the conviction, and the importance of the witness's testimony.
The court concluded that the trial court properly admitted Dora's conviction testimony, as it provided relevant insight into his potential bias, consistent with the precedent established in Johnson v. State, which allows for the impeachment of a witness on grounds of bias or prejudice.
Baldwin contends that the trial court erred by not adequately articulating its findings regarding the Peterson criteria, claiming reversible error. However, despite the judge's lack of explicitness, it is evident that the decision was rooted in a comprehensive evaluation of the testimony and relevant evidentiary rules. Any potential error regarding the Peterson findings is deemed harmless, supported by precedents in Johnson and Smith. Furthermore, Baldwin introduced evidence of Dora's prior incarceration, which negates his claim of unfair prejudice since he was the first to reference Dora's criminal history. The court found no abuse of discretion in allowing testimony about Dora's prior conviction, rejecting Baldwin's assignment of error.
In addressing the State's closing argument, Baldwin argues that the prosecutor improperly commented on his failure to testify. The State counters that the comment did not pertain to Baldwin's silence. Upon review, it is determined that the prosecutor's remarks were a legitimate response to Baldwin's assertion regarding Bryan Dill's freedom, without directly referencing Baldwin's choice not to testify. The trial court supported this interpretation, leading to the conclusion that this assignment of error lacks merit.
Finally, Baldwin's assertion that the verdict is against the overwhelming weight of the evidence is examined. He argues that the jury was biased by graphic evidence and the case against Darnell Baldwin and Bryan Dill.
Baldwin claims no physical evidence links him to the crime and asserts he has an alibi for the relevant evening. The court notes that when evaluating a jury's verdict for being against the overwhelming weight of the evidence, it must accept supporting evidence as true and can only reverse if the trial court abused its discretion in denying a new trial. A verdict may only be disturbed on appeal if it is found to sanction an unconscionable injustice. The prosecution is entitled to all reasonable inferences from the evidence, and issues of weight and credibility are for the jury to resolve.
Baldwin's arguments concerning the admission of photographs and evidence against co-defendants have been previously addressed and are deemed meritless, as convictions can stand without physical evidence. Citing past cases, the court highlights that eyewitness testimony can suffice for a conviction despite issues with credibility. Baldwin's alibi is weakened by a lack of witness testimony accounting for him between 12:45 a.m. and 5:00 a.m., coinciding with the estimated time of the murder.
The record contains sufficient evidence to uphold the jury's verdict, including testimony from Detective Tony Mulligan regarding inconsistencies in Bryan Dill's statements, admissions from Clint Baldwin detailed by Stanley Abrams, and physical evidence found at the murder site, corroborated by Dr. Steven Hayne's expertise on the weapon that caused Liz Dill's fatal wound.
Michael Ball testified that while incarcerated with Clint Baldwin, Baldwin revealed he was paid $5,000 to dispose of a body, admitting that when he and his brother Darnell arrived, the woman was still alive. They subsequently killed her and disposed of her body in a remote location. A vehicle belonging to Darnell Baldwin was found burned in Alabama. Cindy Hosli testified that Clint Baldwin threatened her following her conversation with Deputy Marc Miley, and Clint lacked a solid alibi during the relevant time period. Upon reviewing the evidence favorably towards the verdict, the court found it did not contradict the overwhelming weight of the evidence, despite some witness credibility issues and minor discrepancies. The court affirmed Clint Baldwin's conviction for capital murder and his life sentence, which will run consecutively with any other sentence he is serving. A dissenting opinion was offered by Justice Banks, who argued that the prosecutor improperly commented on the defendant's failure to testify, which he deemed a violation of the defendant's constitutional rights and grounds for a new trial.
