Hartfield v. State

• Decision Date: 05 March 2015
• Docket Number: No. 2012–CT–01232–SCT.,2012–CT–01232–SCT.
• Citation: 161 So.3d 125
• Parties: Joseph Ronald HARTFIELD a/k/a Ronald “Drew” Hartfield v. STATE of Mississippi.
• Court: Mississippi Supreme Court

161 So.3d 125

Joseph Ronald HARTFIELD a/k/a Ronald “Drew” Hartfield

v.STATE of Mississippi.

No. 2012–CT–01232–SCT.

Supreme Court of Mississippi.

March 5, 2015.

Rehearing Denied April 30, 2015.

Robert Greer Whitacre, attorney for appellant.

Office of the Attorney General by Stephanie Breland Wood, attorney for appellee.

EN BANC.

Opinion

CHANDLER, Justice, for the Court:

¶ 1. A jury convicted Ronald Hartfield of conspiracy to murder his wife but acquitted him of her murder. The Circuit Court of Lamar County sentenced Hartfield to twenty years in the custody of the Mississippi Department of Corrections. Hartfield appealed, and this Court assigned the case to the Court of Appeals. 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 under Mississippi Rule of Evidence 804(b)(3). This Court granted the State's petition for certiorari to address that issue.

¶ 2. We find 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, we rule on those issues. We find that the trial court's denial of the peremptory challenge was not clearly erroneous. We further find that the evidence was sufficient to support Hartfield's guilt of conspiracy, and that the verdict of guilt was not against the overwhelming weight of the evidence. Therefore, we reverse the judgment of the Court of Appeals and reinstate and affirm the judgment of the Circuit Court of Lamar County.

FACTS

¶ 3. Tabitha Hartfield was murdered on the night of May 24, 2008. That night, Hartfield, Tabitha, Tabitha's cousin Natasha Graham, and Cody Dixon were at Graham's residence, a trailer located in rural Lamar County. After an argument with Hartfield, Tabitha tried to leave in Hartfield's car, but she wrecked the car in a pond dam on the property. Tabitha got out of the car and wandered down the driveway while Hartfield and Dixon tried, unsuccessfully, to dislodge the car from the pond dam. Hartfield, Graham, and Dixon each gave conflicting stories as to what happened next. Hartfield said that when he realized the car was stuck, he went inside and fell asleep. He denied any involvement in the murder and stated that he first learned Tabitha was dead after Graham reported the murder to police on May 31, 2008. But Hartfield's cellmate, Joseph Bryant, testified that Hartfield told him that Hartfield and his girlfriend had discussed killing his wife, and then they strangled her with a dog leash and buried her in the woods.

¶ 4. Dixon testified that Graham and Tabitha had fought earlier that evening due to Tabitha's suspicion that Graham was having an affair with Hartfield. He testified that, after Tabitha wrecked the car, Graham crushed some pills, mixed them in a glass of water, and brought the glass to Tabitha, who drank the mixture. Then, he and Hartfield walked over to Tabitha, and Hartfield strangled her with a dog leash. Dixon testified that Tabitha was too intoxicated to resist. Dixon testified that, while Hartfield was strangling Tabitha, a vehicle approached, and he and Hartfield hid and left Tabitha lying in the driveway. Jeremy Gibson was driving the vehicle. Dixon said that, when Gibson saw Tabitha, he honked and then turned around and left, but quickly returned and drove to the trailer, where he spoke briefly with Graham before departing. After a few minutes, Dixon and Hartfield returned to Tabitha, and Hartfield strangled Tabitha to death with the leash. Dixon testified that Graham came out, cut Tabitha's wrists with a kitchen knife, and helped wrap her body in a blanket. The three put Tabitha's body on a trailer attached to a lawn mower and, the next morning, Dixon and Graham drove the lawn mower into the woods and buried the body in a shallow grave. Dixon testified that Hartfield instructed him to “take the blame” if the police got involved.

¶ 5. Gibson testified that, as he drove down the driveway, he observed Tabitha lying in the road, honked, and yelled at her to move. Tabitha sat up and looked at him, then lay back down. Gibson testified that, initially, he drove away after seeing Tabitha because he did not get along with her husband, Hartfield, but then he changed his mind and drove back to the trailer. This time, Tabitha did not move when he honked, and he drove around her. Gibson stated that, through the trailer's window, he saw Hartfield sitting at the kitchen table. Gibson also testified that he saw Dixon pop his head out of a window. Gibson testified that Graham walked outside, and he told her he wanted pills; she replied that it was not a good time. Then, Hartfield came outside, and Gibson left.

¶ 6. Dixon admitted that his testimony was the result of a favorable plea bargain. He also admitted that his trial testimony differed from his earlier statements to the police. On May 31, 2008, Dixon told the police that he had strangled Tabitha, and that, at the time of the murder, Hartfield had been asleep inside and had no knowledge of Tabitha's murder. After that statement, Dixon wrote several letters to investigators offering to assist with the State's case in exchange for a favorable plea deal. Finally, on June 2, 2011, Dixon told the police that Hartfield had killed Tabitha. But in an August 29, 2011, letter to investigators, Dixon admitted that he had falsely implicated Hartfield to save himself. Dixon denied that he had written that letter.

¶ 7. Graham reported the murder to the authorities on May 31, 2008. She told a 911 operator that she had killed her cousin. Officer Jason Alexander responded to the call, and Graham led him to the gravesite. Alexander arrested Graham and asked Officer Matt Henderson to drive her to the jail. Henderson testified that, during the trip to the jail, Graham stated that “Dixon was there and he helped. And Mr. Hartfield was there, but in the house ... Hartfield was at the house, but not near where the murder occurred.” At the jail, Graham told Chief Investigator Richard Cox that a blue dog leash had been used to strangle Tabitha. Investigator Cox found two blue dog leashes inside Graham's trailer.

¶ 8. Graham was convicted in a separate trial of murder and conspiracy to commit murder. Graham took the stand at Hartfield's trial but invoked her rights under the Fifth Amendment of the United States Constitution due to her prior conviction and pending appeal. This Court subsequently affirmed Graham's conviction. Graham v. State, 120 So.3d 382, 389 (Miss.2013).

¶ 9. Hartfield sought to introduce several letters Graham had written while awaiting trial to Hartfield, her boyfriend James Decker, and her mother, Diane Breakfield. In the letters, Graham stated that Dixon, acting on his own, had strangled Tabitha while Hartfield was inside asleep, and that Dixon had forced Graham to assist him with disposing of the body. Hartfield argued that these letters were admissible under Mississippi Rule of Evidence 804(b)(3). Mississippi Rule of Evidence 804(b)(3) contains an exception to the hearsay rule providing that, if the declarant is unavailable as a witness, a statement against the declarant's penal interest that exculpates the defendant is admissible if corroborating circumstances clearly indicate the statement's trustworthiness. M.R.E. 804(b)(3). The trial court agreed that Graham was unavailable and that the letters were against her penal interest but excluded the letters on the ground that they were uncorroborated and lacked indicia of trustworthiness. The Court of Appeals reversed and remanded for a new trial, finding that Graham's statements in the letters were against her penal interest and sufficiently corroborated by the police statements given by Hartfield and Dixon, the autopsy findings, and other evidence. This Court granted the State's petition for certiorari. Because we find that Graham's statements were not against her penal interest, we do not reach the issue of whether corroborating circumstances indicated the statements were trustworthy.

DISCUSSION

I. THE TRIAL COURT DID NOT ABUSE ITS DISCRETION BY EXCLUDING GRAHAM'S LETTERS.

¶ 10. This Court reviews the trial court's ruling admitting or excluding evidence for abuse of discretion. Whitaker v. State, 146 So.3d 333, 337 (Miss.2014). Additionally, an evidentiary ruling will not be disturbed unless the error affected a substantial right of a party. M.R.E. 103(a).

¶ 11. It is undisputed that Graham's letters to Hartfield, Decker, and Breakfield constituted hearsay. Under Mississippi Rule of Evidence 802, “[h]earsay is inadmissible except as provided by law.” Rule 804 contains hearsay exceptions applicable when the declarant is unavailable as a witness. Rule 804(b)(3) states:

Statement Against Interest. A statement which was at the time of its making so far contrary to the declarant's pecuniary or proprietary interest, or so far tended to subject him to civil or criminal liability, or to render invalid a claim by him against another, that a reasonable man in his position would not have made the statement unless he believed it to be true. A statement tending to expose the declarant to criminal liability and offered to exculpate the accused is not admissible unless corroborating circumstances clearly indicate the trustworthiness of the statement.

M.R.E. 804(b)(3). The rule imposes three requirements for the admission of a statement that tends to expose the declarant to criminal liability and is offered to exculpate the accused: (1) that the declarant is unavailable as a witness, (2) that the statement so far tends to subject the declarant to criminal liability that a reasonable person in his position would not have made the statement unless he believed it to be true, and (3) that corroborating circumstances clearly...