The Mississippi Court of Appeals has granted a new trial to a West Point woman convicted of first-degree murder in a decision handed down Tuesday.
A Clay County Circuit Court jury convicted Tameshia Shelton, 47, in 2015 of the shooting death of her sister’s 21-year-old boyfriend Danelle Young.
During Shelton’s trial, the medical examiner who performed Young’s autopsy testified that Young’s gunshot wound was consistent with that of a .22-caliber handgun. The medical examiner said that the pathway of the bullet – straight back and down – was more indicative of homicide than suicide, which was Shelton’s primary defense.
Shelton was sentenced to life imprisonment with the Mississippi Department of Corrections.
In 2020, the Mississippi Innocence Project won permission from the Mississippi Supreme Court to file a petition on Shelton’s behalf for post-conviction relief. Post-conviction relief is a legal process allowing someone convicted of a crime to challenge their conviction or sentence after the direct appeals process.
Through a series of PCR hearings, Shelton argued that the medical examiner’s testimony during her trial was not supported by scientific evidence and that the trial counsel’s performance at trial prejudiced her defense. The circuit court denied the PCR motion in March 2024, finding the original verdict should stand.
Shelton appealed the ruling on four claims, including that the medical examiner had changed his opinion, her trial attorney provided ineffective representation, she was factually innocent and that a witness’ alleged false testimony deprived her of a new trial.
The Court of Appeals sided with Shelton and granted a new trial, ruling that two of those issues – the medical examiner’s change in opinion and the ineffective counsel claim – materially undercut the state’s case and could have resulted in a different outcome for Shelton’s original trial.
Court’s analysis
The medical examiner had originally testified it was “not probable” Young’s death was a suicide due to the straight path of the bullet that killed him. A bullet path skewing to the right or left – due to the nature of the victim holding the gun to his chest – would be more consistent with suicide, he testified.
But the medical examiner recanted that opinion in the PCR proceedings, saying he “had gained more experiences as well as … reviewed scientific articles regarding bullet trajectories in suicides and in homicides.”
Having “revisited the case,” the medical examiner testified that the manner of death – whether suicide or homicide – is undetermined. Additionally, the medical examiner submitted a sworn affidavit saying he sees no evidence to support homicide.
The circuit court ruled the medical examiner’s change of opinion in the manner of Young’s death did not merit a reversal in the case because statistics from studies introduced into evidence strongly suggest that Young’s death was not a suicide.
The Court of Appeals disagreed, ruling that the medical examiner’s recantation was a “scientifically grounded correction that undercut the foundation of the state’s case.”
Shelton also argued her trial attorney failed to adequately challenge the medical examiner’s original claim of homicide by not entering a potential suicide note into the court record.
Shelton claimed she discovered a letter in her child’s baby books months after Young’s death stating, “I pretty much gotta start my life over again. I have no life without (Ketina, Shelton’s sister). These are my last words. … Tell Trin I said Bye and be a good girl ok. Tell Treasure about me one day. Bye Bye.”
Shelton presented a report and testimony from a handwriting expert who identified Young as the person who wrote the letter. Other contents of the letter indicate it was written in close proximity to the time of Young’s death.
Shelton said she provided her attorney, Rod Ray, a copy of the letter before trial, but during the PCR proceedings, Ray testified the trial court would not allow the letter to be introduced. However, after revisiting the record, the Appeals Court could not find where the admissibility of the letter was argued and decided at trial.
“We therefore agree with Shelton’s contention that “the transcript does not show that (Shelton’s trial counsel) ever questioned any witness about the letter,” the court wrote in its ruling. “Nor does the record disclose that he made any efforts at all to secure its admission into evidence.”
On those two issues, the court ruled the circuit court “committed clear error” in denying her PCR motion, reversed the judgement and ordered a new trial. The court found Shelton’s two other claims held no merit.
Judge John Emfinger, joined by Judges Anthony Lawrence and John Weddle, dissented from the majority’s opinion. In his dissent, Emfinger stressed that expert recantations – like that of the medical examiner – are unreliable. Likewise, he agreed statistical studies indicated homicide was the more likely manner of death.
Emfinger also rejected Shelton’s ineffective-assistance claims, citing strategic reason on the defense counsel’s part and that even assuming deficiency, the outcome of Shelton’s trial likely wouldn’t have changed.
McRae is a general assignment and education reporter for The Dispatch.
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