Edmonds v. State

Decision Date29 June 2017
Docket NumberNO. 2015–CA–01788–SCT,2015–CA–01788–SCT
Citation234 So.3d 286
Parties Tyler EDMONDS a/k/a Tyler W. Edmonds v. STATE of Mississippi
CourtMississippi Supreme Court

JIM WAIDE, VICTOR ISRAEL FLEITAS, TUPELO, ATTORNEYS FOR APPELLANT

OFFICE OF THE ATTORNEY GENERAL BY: WILSON DOUGLAS MINOR, JACKSON, ATTORNEY FOR APPELLEE

EN BANC.

COLEMAN, JUSTICE, FOR THE COURT:

¶ 1. In July 2004, an Oktibbeha County jury found Tyler Edmonds guilty of the murder of Joey Fulgham, who was his half-sister's husband. In May 2007, the Mississippi Supreme Court reversed Edmonds's conviction and remanded the case to the Oktibbeha County Circuit Court for a new trial due to evidentiary errors. At his new trial in 2008, a jury found Edmonds not guilty.

¶ 2. The present appeal stems from Edmonds's suit against the State under the Compensation to Victims of Wrongful Conviction and Imprisonment statutes codified in Mississippi Code Sections 11–44–1 to 11–44–15, which permit a person wrongfully convicted and imprisoned to recover $50,000 for every year of wrongful incarceration. The circuit court concluded that Edmonds was not entitled to compensation because he made a false confession to police officers regarding his involvement with the murder, which equated to a fabrication of evidence. Edmonds appeals, and we reverse the judgment and remand the case to the circuit court.

FACTS AND PROCEDURAL HISTORY

¶ 3. In 2003, Edmonds confessed that he, with the help of his half-sister Kristi Fulgham, shot Joey Fulgham. At the time, Joey was married to Kristi. Initially, Edmonds and his mother voluntarily went to the police station, and Edmonds claimed that he did not know anything about the murder. However, Edmonds's mother was removed from the room, Edmonds was informed that Kristi had implicated him in the murder, and Kristi, who was already at the police station, was brought into the room with Edmonds. She held Edmonds's hand and told him that she had told the truth and that he should tell the truth too. After his brief meeting with Kristi, Edmonds gave a confession that he and Kristi had killed Joey. Several days later, Edmonds recanted his confession and stated that Kristi had acted alone in shooting Joey.

¶ 4. Following trial, the jury convicted Edmonds of murder, and the court sentenced him to life in the custody of the Mississippi Department of Corrections. Edmonds appealed, and the Court of Appeals affirmed his sentence and conviction. Edmonds v. State , 955 So.2d 864, 900 (¶¶ 120–1) (Miss. Ct. App. 2006). The Supreme Court granted Edmonds's petition for writ of certiorari review. Edmonds v. State , 955 So.2d 787, 790 (¶ 2) (Miss. 2007). The Court concluded that Edmonds did not receive a fair trial for a variety of reasons, so the Court reversed the circuit court's and Court of Appeals' judgments and remanded the case for a new trial. Id. at 798–9 (¶¶ 29–33).

¶ 5. Edmonds's second trial resulted in a not-guilty verdict. Upon the return of the not-guilty verdict, Edmonds filed the present action seeking compensation pursuant to Section 11–44–1 for the years he spent in custody. Edmonds's bench trial resulted in a determination by the circuit court that Edmonds's confession was fabricated evidence; thus, he could not recover under the Compensation to Victims of Wrongful Conviction and Imprisonment statutes. Edmonds appeals and raises the following issues:

I. Whether the circuit court erred in concluding that Edmonds fabricated evidence.
II. Whether the circuit court's failure to give Edmonds a fair trial at his first criminal trial was a superseding cause of Edmonds's conviction, such that the false confession was not a legal cause of his conviction.
III. Whether the circuit court should have granted Edmonds's request to have a jury trial.

STANDARD OF REVIEW

¶ 6. As has been explained, the present appeal stems from the circuit court's judgment following a bench trial. It is well-settled that the Court defers to the factual findings and determinations of a trial judge sitting as the finder of fact at a bench trial; therefore, we will not disturb such findings if they are supported by substantial evidence and the trial court did not abuse its discretion, was not manifestly wrong, was not clearly erroneous, and did not apply an erroneous legal standard. Covington County v. G.W. , 767 So.2d 187, 189 (¶ 4) (Miss. 2000) (quoting Church of God Pentecostal, Inc. v. Freewill Pentecostal Church of God, Inc. , 716 So.2d 200, 204 (¶ 15) (Miss. 1998) ). As is customary, the Court reviews questions of law, including statutory interpretation, de novo. Tellus Operating Group, LLC v. Texas Petroleum Inv. Co. , 105 So.3d 274, 277–8 (¶ 9) (Miss. 2012) (quoting Laurel Ford Lincoln–Mercury, Inc. v. Blakeney , 81 So.3d 1123, 1125 (¶ 5) (Miss. 2012) ).

ANALYSIS

¶ 7. For purposes of our analysis, the first two issues raised by Edmonds can be consolidated into one issue: the appropriate interpretation and application of Section 11–44–7(1)(c), which provides that a plaintiff under the Compensation to Victims of Wrongful Conviction and Imprisonment Act ("Wrongful Conviction and Imprisonment Act") must show he did not "fabricate evidence to bring about his conviction." See Miss. Code Ann. § 11–48–7(1)(c) (Rev. 2012). The second primary issue before us is whether Edmonds's request for a jury trial should have been granted. On both issues, we hold in favor of Edmonds.

I. Section 11–44–7(1)(c) includes an element of intent to bring about one's conviction when fabricating evidence and therefore, an issue of material fact remains as to Edmonds's intent.

¶ 8. According to Section 11–44–1, the reason for the passage of the Wrongful Conviction and Imprisonment statutes was to provide monetary compensation to "innocent persons who have been wrongly convicted of felony crimes and subsequently imprisoned" because they "have been uniquely victimized, have distinct problems reentering society, and should be compensated." Miss. Code Ann. § 11–44–1 (Rev. 2012). Compensation is provided if a claimant proves by a preponderance of the evidence that "[h]e was convicted of one or more felonies and subsequently sentenced to a term of imprisonment, and has served all or any part of the sentence; and ... his judgment of conviction was reversed or vacated and ... [i]f a new trial was ordered, he was found not guilty at the new trial ...." Miss. Code Ann. § 11–44–7(1)(a)(ii)(2) (Rev. 2012). Further, the claimant must prove that "[h]e did not commit the felony or felonies for which he was sentenced and which are the grounds for the complaint, or the acts or omissions for which he was sentenced did not constitute a felony." Miss. Code Ann. § 11–44–7(1)(b). Finally, and most relevant to the present case, the claimant must prove that "[h]e did not commit or suborn perjury, or fabricate evidence to bring about his conviction." Miss. Code Ann. § 11–44–7(1)(c).

¶ 9. The crux of Edmonds's position is that the circuit court erred in finding that his false confession prohibits him from recovery pursuant to Section 11–44–7(1)(c). In support of his position, Edmonds outlines several facts that led to his confession, which include: his young age, his desire to help his half-sister avoid the death penalty, and the police allowing his half-sister to speak to him without his mother present. Essentially, Edmonds's argument is two-fold: (1) the statute requires an element of intent to fabricate evidence, and (2) an issue of material fact exists as to the nature of Edmond's intent. The State, on the other hand, contends that the "to bring about" language is merely causative and lacks any connotation of intent. We agree with Edmonds on both points.

¶ 10. First, the issue hinges upon the Court's interpretation of the following language within the statute: "[The Claimant] did not ... fabricate evidence to bring about his conviction." Miss. Code Ann. § 11–44–7(1)(c). "When interpreting a statute that is not ambiguous, this Court will apply the plain meaning of the statute." Pitalo v. GPCH–GP, Inc. , 933 So.2d 927, 929 (¶ 5) (Miss. 2006). To determine the plain meaning, "we must look at the words of the statute." Adams v. Baptist Mem'l Hosp.–DeSoto, Inc. , 965 So.2d 652, 656 (¶ 21) (Miss. 2007).

¶ 11. The word "fabricate" has no element of intent indicating ultimate purpose or motive for the fabrication embedded within its plain meaning; however, the phrase "to bring about" does. The word "to" carries many definitions, one of which is "used for expressing aim, purpose, or intention." To , Random House Webster's Unabridged Dictionary 1989 (2d ed. 2001). The phrase "to bring about" reflects the function of the word "to" as expressing "aim, purpose, or intention," as in "[The Claimant] did not ... fabricate evidence [with the "aim, purpose, or intention" of bringing] about his conviction." As it means "[s]omething, esp[ecially] willful desire, that leads one to act," Motive , Black's Law Dictionary (10th ed. 2014), the word "motive" also would be appropriate to describe the requirement at issue. In more technical terms, the phrase "to bring about" produces an adverbial infinitive that modifies and directs the verb "fabricate." Adverbial infinitives frequently are employed to express intent or motive behind a particular action, e.g. , "I went to the store to buy groceries " (i.e. , I went to the store with intent, and that intent was to buy groceries ); "He ran for office to bring about change " (i.e. , he ran for office with intent, and that intent was to bring about change ). Turning the statute into a question simplifies the technical understanding: Why did the claimant fabricate evidence? To bring about his conviction. In other words, the claimant fabricated evidence in order to bring about his conviction, which denotes intention, purpose, or motive. Moreover, no other understanding of the word "to" fits within the context of the phrase "to bring about," and, therefore, a plain reading of the statute engenders an element of intent under subsection (1)(c).

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1 books & journal articles
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    • United States
    • Carolina Academic Press Wrongful Conviction: Law, Science, and Policy (CAP) 2019
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    ...the death penalty and that he falsely confessed only after he spoke with his half-sister in the absence of his mother. Edmonds v. State, 234 So.3d 286 (Miss. 2017). 3. As noted, state compensation statutes sometimes bar persons wrongly convicted via false confessions and/or false guilty ple......

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