Hartfield v. Mississippi
Annotate this CaseA jury convicted Ronald Hartfield of conspiracy to murder his wife but acquitted him of her murder. The circuit court sentenced Hartfield to twenty years in the custody of the Mississippi Department of Corrections. Hartfield appealed. The Court of Appeals reversed and remanded for a new trial based on the trial court’s exclusion of a coconspirator’s letters offered as statements against her penal interest. The Supreme Court granted the State’s petition for certiorari to address that issue. After review, the Court found that the letters were not against the coconspirator’s penal interest and that they were properly excluded by the trial court. Because the Court of Appeals did not address Hartfield’s arguments on the weight and sufficiency of the evidence and the trial court’s denial of one of Hartfield’s peremptory challenges, the Court ruled on those issues: (1) the trial court’s denial of the peremptory challenge was not clearly erroneous; (2) the evidence was sufficient to support Hartfield’s guilt of conspiracy; and (3) that the verdict of guilt was not against the overwhelming weight of the evidence. Therefore, the Supreme Court reversed the judgment of the Court of Appeals and reinstated and affirmed the judgment of the circuit court.
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