Exson v. State of Mississippi
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The case before the Supreme Court of Mississippi involves an appeal by Joe Exson, who was convicted of burglary of a dwelling, grand larceny, and first-degree arson. Exson was identified in a video committing these crimes, wearing a distinctive hoodie that was later found in his possession. He stole numerous items from the property and set it on fire, causing it to burn down entirely. The primary issue in Exson's appeal was the valuation of the stolen items, which was used to determine the charge of grand larceny. The property owner estimated the value of the stolen goods to be over $1,000, which is the minimum threshold for grand larceny under Mississippi law.
Exson argued that the state failed to provide sufficient evidence of the fair market value of the stolen property and that the jury was improperly instructed on the value element of the larceny statute. However, the court noted that Exson failed to raise these arguments during his trial and thus, they were procedurally barred. Besides, the court found no merit in Exson's arguments as he was clearly seen committing the crime in the video. Moreover, reversing his larceny sentence would not substantially change his overall sentence since his arson sentence was longer and was to run concurrently.
The court also examined the jury instructions and found that they tracked the language of the grand larceny statute correctly, even though they did not further define the element of value. Since Exson did not object to the instructions or request a definitional instruction during his trial, the court found no reversible error. Therefore, the Supreme Court of Mississippi affirmed Exson's convictions.
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