Joseph David Heard v. State of Mississippi

Summary

The Mississippi Supreme Court affirmed Joseph Heard's capital-murder conviction and death sentence for the beating death of his wife's two-year-old son, Hayden, rejecting all ten assignments of error. The court held that the waived challenge to Dr. Lee's 'certainty' testimony failed under plain error, that the paramedic's lay testimony was admissible under Rule 701, that the exclusion of a character witness's opinion was an abuse of discretion but not reversible for lack of prejudice, and that Cellebrite cell-phone extraction testimony required neither an expert nor a Rule 702 reliability determination. Sufficient evidence supported the jury's Enmund finding that Heard attempted to kill, the HAC aggravator and instruction, and the proportionality of the sentence; both ineffective-assistance claims were denied on direct appeal and preserved for post-conviction review.