Opposition Brief — Parks v. Mississippi

Opinion Below

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Argument—

There Was No Abuse of Discretion in the Denial of

the Petitioner’s Motion for a Change of Venue,

and There Was Therefore No Denial of Petitioner’s

Right to a Trial by a Fair and Impartial Jury ...... 4

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Table of Authorities

CASES

Anderson v. State, 152 So.2d 702, 246 Miss. 821... 4

Golden v. State, 71 So.2d 476, 220 Miss. 465 4

Grappe v. Wisconsin, 400 U.S. 905, 27 L.Ed.2d 571, 91

I hart eisieccnereton eccserncerutacict wut. 11

Irvin v. Dowd, 366 U.S. 717, 6 L.Ed.2d 751, 81 S.Ct.

SESE CR eave aaa Da ay an 11

Kersten v. U. S., 161 F.2d 337, 67 S.Ct. 1744, 331 US.

INI UI iad cece 4

McGee v. State, 40 So.2d 160, 70 S.Ct. 77, 338 U.S. 805,

94 L.Ed. 487, 70 S.Ct. 977, 399 USS. 958, 94 L.Ed. 1369 4

Miller v. U. S., 287 Fed. 864, 43 S.Ct. 705, 262 U.S. 758,

67 L.Ed. 1219 4

Parks v. State, 267 So.2d 302 i 3... | ee 1

Rideau v. Louisiana, 373 U.S. 723, 10 L.Ed.2d 663, 83

S.Ct. 1417

TEXTS AND STATUTES

Federal Rules of Criminal Procedure, Rule 21(a), 18

US.C.A.

Ty $e

TEE MPLA IOS RINT SH SERIE YE MET AE YI WL SE ig

In the Supreme Court of the United States

OCTOBER TERM

No. 72-1012

WESLEY PARKS,

Petitioner,

vs.

STATE OF MISSISSIPPI,

Respondent.

PETITION FOR A WRIT oF CERTIORARI

TO THE SUPREME Court oF

MISSISSIPPI

BRIEF IN OPPOSITION

OPINION BELOW

The opinion of the Supreme Court of Mississippi (pe-

titioner’s appendix) is reported as Parks v. State, 267 So.2d

302 (Miss. 1972).

JURISDICTION

Jurisdictional prerequisites are adequately set forth

in the petition.

QUESTION PRESENTED

Was the denial of the petitioner’s motion for a change

of venue an abuse of discretion which operated to deprive

him of a trial by a fair and impartial jury?

STATEMENT OF FACTS

The petitioner, Wesley Parks, was indicted by the

Grand Jury of Sunflower County, Mississippi, on a charge

of the murder of one Joetha Collier on May 25, 1971,

Under that indictment, the petitioner was tried in the

Circuit Court of Sunflower County, found guilty of the

crime of manslaughter, and was sentenced to a term of

twenty years in the state penitentiary. The petitioner

appealed said conviction to the Supreme Court of Missis-

sippi, wherein the conviction and sentence were affirmed.

The crime for which petitioner stands convicted at-

tracted a considerable amount of publicity, both local and

national, The basic facts of the crime are substantially

undisputed. The petitioner and two others were riding in

an automobile down a street in the business district of

Drew, Mississippi. The petitioner, a passenger in the ve-

hicle, was armed with a 22-caliber pistol which he fired

out of the window of the moving vehicle with the bullet

—

3

striking and killing one Joetha Collier who was standing

with others on the sidewalk in front of a cafe. The pe-

titioner is a white man. Joetha Collier was a teenaged

colored female who had that day graduated from high

school. Sunflower County, Mississippi, like most other

Mississippi counties in that area, has a large percentage

of negroes; in the case of Sunflower County, approximately

fifty percent. The senseless killing of the young girl ap-

parently caused a considerable amount of indignation and

concern in both the white and black communities. The

petitioner and his two companions, following their arrest,

were held at the Mississippi State Penitentiary (also lo-

cated in Sunflower County) instead of in the county jail at

Indianola, Mississippi, because of some unrest in the negro

community. The petitioner filed a motion for a change of

venue on June 14, 1971, and that motion was denied by the

Circuit Court of Sunflower County, but the court left the

matter open for further review prior to trial. The motion

for a change of venue was renewed, and a second hearing

on the motion was had on October 18, 1971, with the court

again overruling the motion. Petitioner went to trial on

October 26, 1971.

The petitioner now seeks to have this court grant

certiorari in order to determine whether he was deprived

of his right to a trial by a fair and impartial jury resulting

from a denial of motions for a change of venue,

ARGUMENT

There Was No Abuse of Discretion in the Denial of the

Petitioner’s Motion for a Change of Venue, and There

Was Therefore No Denial of Petitioner’s Right to a

Trial by a Fair and Impartial Jury.

The rule, as it must necessarily be, is almost uni-

versally the same in state and federal court practice; that

is, that rulings on motions for changes of venue are ad-

dressed to the sound discretion of the trial court, and the

trial court’s rulings will not be disturbed except upon a

clear showing of abuse of discretion, e.g., Miller v. U. S.,

287 Fed. 864, certiorari denied, 43 S.Ct. 705, 262 U.S. 758,

67 L.Ed. 1219; McGee v. State, 40 So.2d 160, appeal dis-

missed, certiorari denied, 70 S.Ct. 77, 338 U.S. 805, 94 L.

Ed. 487, rehearing denied, 70 S.Ct. 977, 399 U.S. 958, 94

L.Ed. 1369; Golden v. State, 71 So.2d 476, 220 Miss. 465;

Anderson v. State, 152 So.2d 702, 246 Miss. 821; Fed. Rules

of Criminal Procedure, Rule 21(a), 18 U.S.C.A.; Kersten

v. U. S., 161 F.2d 337, certiorari denied, 67 S.Ct. 1744, 331

U.S. 851, 91 L.Ed. 1859.

As a corollary to the rule cited above, there is, of

course, the rule that in determining whether or not there

has been an abuse of discretion, the appellate court will,

as it necessarily must, look to the “totality of circum-

stances” in determining the issue.

What, then, are the “totality of circumstances” in this

particular case?

It is manifest from the record, and from the brief in

support of the petition filed in this court, that petitioner

is relying on what he terms “reverse discrimination,” and

which he defines, in effect, as being a situation where the

5

negro community of Sunflower County was so infected

with prejudice and ill will toward the defendant that a

fair and impartial jury could not be obtained when at

least a portion of the jury was certain to be made up of

negroes.

One of the factors, of course, to be considered in mat-

ters such as this is whether or not it appears from the

record that the petitioner did, in fact, receive a fair and

impartial trial, even assuming, arguendo, that there was

some degree of prejudice and ill will toward the defendant

in the community.

There is no claim by the petitioner nor any indication

in the record that any member of the trial jury was dis-

qualified for any reason other than the assumption on the

part of the petitioner that the nature and extent of the

pretrial publicity and events necessarily infected the en-

tire proceedings. The petitioner apparently did not re-

quest that the voir dire of the trial jury be taken, and

there is no indication in the record as to whether or not

it was necessary for the ‘petitioner to exhaust all peremp-

tory challenges. The only reference in the record as to the

selection of the trial jury is as follows:

“(The Jury was selected during October 26, 1971 and

| October 27, 1971. The jurors, after being sworn, were

| instructed by the Court, then were given a short re-

| cess. )

“IN CHAMBERS, OUT OF THE PRESENCE AND

THE HEARING OF THE JURY: (After selection of

Jury, October 27, 1971)

“BY THE COURT:

“Let the record show that two hundred veniremen

were drawn by the Court for a special venire in this

~~

a

case. Of that number, sixty-nine were not served

with summons; 131 were served with summons; of

this 131, 29 were excused by the Court prior to em-

paneling the jury, for good cause shown; seven did

not appear in Court; 95 of the special venire actually

appeared in Court; of this number, 45 were excused

by the Court for good cause shown, or were disqual-

ified under the law from serving. Thirteen of this

number were excused by the Court for having fixed

opinions.

“There were 24 regular jurors for the week. Of this

number, three were excused by the Court for good

cause shown; 11 were excused by the Court for having

§ fixed opinions. To obtain the jury of twelve plus the

two alternates, the special venire and the 24 regular

jurors for the week were exhausted, with the excep-

tion of six regular jurors for the week.

ae al

“The final composition of the regular jury of twelve

is eight blacks and four whites. Alternate No. 1 is

black; alternate No. 2 is white.

ican en ee Ores ae ee

“MOTION”

“BY MR. DYER:

“Comes now the defendant, and considering the com-

position of the jury and considering the difficulty

which the Court had in obtaining a jury of twelve,

does now respectfully renew his Motion for a Change

of Venue.

“BY THE COURT:

“The Court has had an opportunity to observe all

these jurors and prospective jurors during the course of

empaneling the jury, and the Court feels that a fair

SY UAE eno TS DA ARE! ALORA le ih fa tho ty Pat

_

and impartial jury has been empaneled. The Court is

going to overrule the motion.

7

* * *~

“(The Jury returned to the Cour troom, and all wit-

nesses were sworn. The rule was invoked.)”

Respondent’s analysis of the statistics is that of a total

of 148 veniremen who were actually present in court, a

total of 24 were excused by the court for having fixed

opinions. This is approximately eighteen percent.

Respondent believes that the observation of the trial

court that the court had observed the jurors and felt that

a fair and impartial jury had been empaneled is entitled

to great weight. Respondent further feels that this is

particularly true when taken into consideration with the

court’s prior actions and observations on the two separate

hearings afforded the petitioner on his motions for change

of venue. After the first hearing, the court entered an

order on June 17, 1971, wherein the first motion was over-

ruled with the court expressing its opinion that a fair and

impartial trial could be held. That order read as follows:

“IN THE CIRCUIT COURT OF SUNFLOWER

COUNTY, MISSISSIPPI

“STATE OF MISSISSIPPI VS. NO. 7522 WESLEY

PARKS, WAYNE PARKS AND ALLEN WILKER-

SON, DEFENDANTS

“ORDER

“This day this cause coming on for hearing on motion

by the severed defendants, Wesley Parks, Wayne

Parks and Allen Wilkerson, they being represented

by counsel, for a change of venue and the court having

heard and considered the same and evidence having

a

been had and adduced thereasto by the State and

Defense, and the court being of the opinion that the

defendants, Wesley Parks, Wayne Parks and Allen

Wilkerson, can now be afforded a fair and impartial

trial in Sunflower County, Mississippi, it is the opinion

of this court that said Motion for Change of Venue

should be and the same is hereby DENIED.

“ORDERED AND ADJUDGED, on this the 17th day

of June, A. D., 1971.

“/s/ Arthur B. Clark, Jr., Circuit Judge”

8

Following the second hearing on the renewed motion

for change of venue, the court ruled as follows:

“RULING OF THE COURT:

“T have heard the testimony and I have had an op-

portunity to observe the witnesses as they testified.

: I note that most of the witnesses for the defendants

] are from around Drew, and even some of those testi-

: fied that they thought they could get a fair trial. The

: defendants presented very few witnesses from outside

District 5, that is, the Drew community.

“T feel, after listening to this testimony, that these de-

fendants can get a fair trial in this county. I am going

to overrule this motion, but I want to say this to you

gentlemen—as I recall, the Supreme Court has said

that, in passing on a motion for a change of venue,

whether or not the trial judge held correctly on that,

they look at the entire record in the case. Now, I can

assure you that when we start the trial of this case, I

am going to question this panel very carefully, and if

I find that a large percentage of that panel expresses

a fixed 2pinion, I will probably reconsider the motion

at that time. I just want you to know that I am de

i ct 6 aha NEN a

_

9

termined that these defendants are going to get a fair

trial, and I will take another look at it when it comes

time to select this jury.

“BY MR. DYER:

“Thank you, Your Honor.”

The opinions expressed on the motions for a change

of venue were, of course, conflicting. It appears from the

remarks of the trial court that most of those testifying in

favor of the motion were friends and/or neighbors of the

petitioner and that petitioner’s evidence did not reflect

the feelings of a representative sample of a cross section

of the population of the county.

It, therefore, appears manifest to respondent that the

trial court at several points gave careful consideration to

the motions for change of venue, and in the exercise of its

sound judicial discretion, concluded that a fair and im-

partial trial could be afforded the petitioner in Sunflower

County, Mississippi.

The crime and arrest of petitioner took place during

the last week of May, 1971. The trial took place during

the last week of October, 1971, or some five months later.

That the passion over the commission of the crime gener-

ated in some elements of one part of the community in

Sunflower County was no longer a factor is strongly in-

dicated by the action of the petitioner himself. Following

the arrest of the petitioner and his companions, they were

taken and held in another area of the county; but on Au-

gust 5, 1971, on motion of the defendants, they were trans-

ferred to the county jail at Indianola, Mississippi. This

appears indicative that there was no longer any cause for

concern as to their safety.

bors.

ee

mang

10

The respondent believes that another factor strongly,

if not conclusively, supporting the proposition that the

petitioner received a fair and impartial trial is the verdict

of the jury finding him guilty only of manslaughter. The

petitioner was indicted for murder. There was evidence

on the trial of the case that the petitioner had pointed his

weapon at at least one other colored person, and respond-

ent believes that that, along with other factors in the

case, would have been sufficient to support a conviction

of murder. Nevertheless, a jury composed of eight blacks

and four whites convicted the petitioner only of man-

slaughter, to which charge the petitioner, in effect, offered

no defense whatsoever. Petitioner avers in his brief that

the circumstances of this crime were such that a jury of

reasonable men could have acquitted him. He bases this

assertion on petitioner’s claim during trial that he was

unaware of the fact that the bullet he fired actually struck

someone. That is, he claims that by such an assertion

he thereby set up a defense of accident or misfortune.

The undisputed facts in this case were that the petitioner

fired a deadly weapon toward a group of people in a

business district of a town, with said actions resulting in

the death of one of those people. The element of intent

under Mississippi law goes only to the murder charge and

not to the manslaughter charge; and since the petitioner

was given the benefit of the doubt as to his intent and

found guilty only of manslaughter, respondent avers that

under the circumstances of this case such a finding on the

part of the jury is strongly persuasive evidence as to the

fairness and impartiality of the said jury.

NS A ee en

That the circumstances of the death of Joetha Collier

attracted considerable publicity, both local and national,

and that it caused indignation and tension in the com-

munity for a period of time cannot be disputed. How-

Piet adil ind aden

11

ever, the tenor of publicity Surrounding these events was,

in appellee’s view, more conducive to encouraging the

orderly processes of justice than to deny them. Where the

reporting of the events was more than a simple factual

presentation of the matter, it was more likely than not

to be of the tenor of an article dated Thursday, June 3,

1971, published in the Sunflower County News, and which

is attached hereto as Exhibit “A”. In short, the pretrial

publicity merely reported events and pictured a community

which was concerned but one in which the overwhelming

majority simply wished to see the normal processes of

justice take place.

It is to be further noted that there is no claim nor in-

dication of any improper or prejudicial action on the part

of any public official.

This case does not in any way approach the factual

or legal situation in those cases cited by the petitioner in

support of his argument.

In Grappe v. Wisconsin, 400 US. 505, 27 L.Ed.2d 571,

91 S.Ct. 490, the question was not whether or not petitioner

should have been granted a change of venue, but rather

whether or not he was entitled to a hearing on a motion

for a change of venue in the face of a Wisconsin statute

denying a change of venue on a misdemeanor charge.

In Irvin v. Dowd, 366 U.S. 717, 6 L.Ed.2d 751, 81 S.Ct.

1639, the question therein was whether or not the peti-

tioner was entitled to a second change of venue in the face

of the Wisconsin statute limiting a defendant to one change

of venue. There, the following factual situation is out-

lined:

“It cannot be gainsaid that the force of this continued

adverse publicity caused a sustained excitement and

; —_

ry

12

fostered a strong prejudice among the people of Gib-

son County. In fact, on the second day devoted to

the selection of the jury, the newspapers reported that

‘strong feelings, often bitter and angry, rumbled to

the surface,’ and that ‘the extent to which the multiple

murders—three in one family—have aroused feelings

throughout the area was emphasized Friday when 27

of the 35 prospective jurors questioned were excused

for holding biased pretrial opinions. . . . A few days

later the feeling was *described as ‘a pattern of deep

and bitter prejudice against the former pipe-fitter.’

[*366 US 727] Spectator comments, as printed by the

newspapers, were ‘my mind is made up’; ‘I think he

is guilty’; and ‘he should be hanged.’

“Finally, and with remarkable understatement, the

headlines reported that ‘impartial jurors are hard to

find.’ The panel consisted of 430 persons. The Court

itself excused 268 of those on challenges for cause as

having fixed opinions as to the guilt of petitioner; 103

were excused because of conscientious objection to

the imposition of the death penalty; 20, the maximum

allowed, were peremptorily challenged by the peti-

tioner and 10 by the State; 12 persons and two aliter-

nates were selected as jurors and the rest were &x-

cused on personal grounds, e.g., deafness, doctor’s or-

ders, etc. An examination of the 2,783-page voir dire

record shows that 370 prospective jurors or almost

90% of those examined on the point (10 members of

the panel were never asked whether or not they had

any opinion) entertained some opinion as to guilt—

ranging in intensity from mere suspicion to absolute

certainty. A number admitted that, if they were in

the accused’s place in the dock and he in theirs on the

-_

13

jury with their opinions, they would not want him on

a jury.

“Here the ‘pattern of deep and bitter prejudice’ shown

to be present throughout the community, cf. Stroble

v California, 343 US 181, 96 L ed 872, 72 S Ct 599, was

clearly reflected in the sum total of the voir dire ex-

amination of a majority of the jurors finally placed in

the jury box. Eight out of the 12 thought petitioner

was guilty. With such an opinion permeating their

minds, it would be difficult to say that each could

exclude this preconception of guilt from his delibera-

tions.”

The factual situation in Rideau v. Louisiana, 373 US.

723, 10 L.Ed.2d 663, 83 S.Ct. 1417 also does not bear any

reasonable resemblance to the factual Situation in this case.

There, a confession of the defendant was publicized at

various times over the local television station, and mem-

bers of the jury had seen and heard the same, and fur-

ther, two members of that jury were deputy sheriffs of

the parish in which the defendant was being tried.

Petitioner cites a number of cases rendered by the

Mississippi Supreme Court, all of which are merely proof

that the said court gives careful consideration to each

case where this issue is raised. Such consideration was

given in this case, and the Mississippi Supreme Court, find-

ing no abuse of discretion on the part of the trial court,

properly affirmed the conviction and sentence.

Ne ae ae

ABER RI

ee

LER BESET:

6 St

| cee

14

CONCLUSION

Respondent avers that petitioner has wholly failed

to meet the burden of proof required of him to show that

he has been denied his constitutional right to trial by a

fair and impartial jury, and, as a consequence thereof, his

petition for a writ of certiorari to this court should be

denied.

Respectfully submitted,

A. F. SUMMER

Attorney General

Special Assistant Attorney General

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