Relious Densmore v. State

Summary

The Supreme Court of Mississippi reversed Relious Densmore’s conviction for sale of cocaine and remanded for a new trial. The court held that the State violated its discovery obligations by disclosing the identity of its confidential informant, who was the prosecution’s principal eyewitness, on the morning of trial and that a brief continuance was insufficient. A dissenting opinion argued that the defense had not shown prejudice and that the continuance granted was reasonable under the circumstances.

Holdings

1. Because Spraggins was the State's main witness and the only eyewitness to the events underlying the charge, the prosecution was required to disclose his name and address before the day of trial under Uniform Circuit and County Court Rules 9.04(A)(1) and 9.04(B)(2).
2. The trial court committed reversible error by refusing to grant a reasonable continuance after the State disclosed the identity of its principal witness on the morning of trial.
3. When a continuance motion is based on the State's last-minute disclosure of a key piece of evidence and the error is apparent from the trial record, the defendant is not required to reassert the issue in a motion for a new trial to preserve it for appellate review.

Questions Presented

1. Whether the State violated Mississippi criminal-discovery rules by disclosing the identity of its confidential informant, the principal eyewitness, on the morning of trial.
2. Whether the trial court erred by denying a reasonable continuance after the State's eleventh-hour disclosure.
3. Whether the defendant was required to reassert the denial of the continuance in a motion for a new trial to preserve the issue for appellate review.

Disposition

reversed_and_remanded