Hartfield v. State
Mississippi Court of Appeals
168 So. 3d 1101 (2014)
Facts
Joseph Hartfield (Hartfield) (defendant), Natasha Graham, and Ethan Dixon were charged with the murder of Tabitha Hartfield and conspiracy to commit the murder. Dixon confessed to committing the murder. Graham’s trial was prior to Hartfield’s. Graham was convicted of murder and conspiracy, and she appealed. Hartfield’s trial took place while Graham’s appeal was pending. At Hartfield’s trial, Graham invoked her Fifth Amendment privilege against self-incrimination, making her unavailable as a witness. Hartfield sought to introduce a series of letters Graham had written that tended to exculpate Hartfield and inculpate Graham and Dixon. In the letters, Graham stated that she helped with Tabitha’s murder. The letters included details of the murder that were consistent with the autopsy report. Finally, the letters indicated that Hartfield took no part in the murder. The trial court excluded the letters as hearsay. Hartfield was convicted of conspiracy, and he appealed.
Rule of Law
Issue
Holding and Reasoning (Griffis, J.)
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