Tuesday, February 26, 2013

State v. Guthrie case brief

State v. Guthrie case brief summary
461 S.E.2d 163

SYNOPSIS: Defendant appealed the jury verdict of the Circuit Court of Kanawha County (West Virginia), which found him guilty of first-degree murder under W.Va. Code § 61-2-1. Defendant was sentenced to serve a life sentence with a recommendation of mercy. Defendant asserted cumulative error based on erroneous jury instructions and improper questions and comments made by the prosecution.

-After being harassed by a co-worker, defendant fatally stabbed the man with a knife. Defendant was convicted of first-degree murder under W.Va. Code § 61-2-1 and sentenced to life in prison.

-The court reversed, holding that the trial court erroneously admitted prejudicial statements allegedly made by defendant about blacks, women, and Hitler that inferred he was a racist, sexist, and Nazi.

-The doctrine of curative admissibility did not apply because the statements had no relation to the crime.
-The prosecution's failure to disclose before cross-examination a statement allegedly made by defendant was also prejudicial and the cumulative error denied defendant his constitutional right to a fair trial.
-After adopting a new standard for determining the sufficiency of the evidence that permitted circumstantial evidence to support a conviction, the court determined that there was sufficient evidence of first-degree murder and remanded the case for a new trial.
-The court also adopted a new instruction defining premeditation for first-degree murder, holding that there must be some evidence that defendant considered and weighed his decision to kill to establish premeditation.

OUTCOME: The court reversed defendant's conviction for first-degree murder and remanded the case for a new trial. The court established new definitions for premeditation and the sufficiency of the evidence.

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