Buchanan v. State

An SUV pulled alongside another vehicle and opened fire. D’Alandis Love died, and the vehicle’s other passengers were seriously injured. Police suspected Armand Jones, Sedrick Buchanan, Michael Holland, Jacarius Keys, and James McClung (defendants). Keys went to the police and made a confession that implicated the others. After Keys, Jones, Buchanan, Holland, and McClung were indicted, but before trial, Keys was fatally shot. Police suspected Holland and Buchanan. Although Jones was incarcerated at the time, there was evidence of communications between him and the others. Keys had also visited Jones’s attorney to explain his confession, suggesting Jones was aware of the confession. Before trial, Jones, Buchanan, Holland, and McClung moved to exclude Keys’s videotaped confession from evidence, arguing that it was inadmissible hearsay and that its admission would violate the Confrontation Clause because they could not cross-examine Keys. The trial court admitted the confession, relying in part on forfeiture by wrongdoing as a hearsay exception and a waiver of confrontation rights. Jones was convicted of murder and attempted murder, and Buchanan was convicted of aggravated assault. After the appellate court affirmed the convictions, Jones and Buchanan appealed to the Mississippi Supreme Court. Jones argued that the trial court erred in admitting Keys’s confession as evidence against him.