Chandler v. State

Summary

The Supreme Court of Mississippi reviewed Joey Montrell Chandler's murder conviction and life sentence for the shooting death of Emmitt Chandler. The court held that the trial court properly refused instructions on culpable-negligence manslaughter and reasonable self-defense because the evidence did not support them, and it addressed the exclusion of hearsay evidence offered to support self-defense. The appeal was denied.

Holdings

1. The trial court properly refused the culpable-negligence manslaughter instructions because the evidence did not provide a sufficient basis for a reasonable jury to find culpable negligence rather than murder, and the jury was otherwise given an adequate manslaughter instruction based on imperfect self-defense.
2. The trial court properly refused reasonable self-defense instructions because the evidence did not support a reasonable self-defense theory; Chandler deliberately armed himself in advance and was therefore the aggressor, and the jury received adequate instructions on imperfect self-defense and accident or misfortune.
3. The exclusion of McCurry's statement was proper because it was offered for the truth of the matter asserted and was hearsay. Chandler's challenge to the exclusion of Ewing's statement was procedurally barred because he made no contemporaneous argument or objection preserving the issue; in any event, Chandler presented substantially the same fear-and-rumors evidence to the jury, making any error harmless.

Questions Presented

1. Whether the trial court erred by refusing culpable-negligence manslaughter instructions.
2. Whether the trial court erred by refusing reasonable self-defense instructions.
3. Whether the trial court erred by excluding statements offered to support Chandler's claim of self-defense.

Disposition

affirmed