## Facts

- Joseph Ronald Hartfield (Hartfield), Natasha Graham, and Ethan Dixon were charged in Lamar County, Mississippi, with the murder of Tabitha Hartfield (Hartfield’s wife) and conspiracy to commit that murder.
- On May 31, 2008, the Lamar County Sheriff’s Department received a 911 call from Graham claiming she had killed her cousin.
- Officer Jason Alexander located Graham near the area she identified; Graham told him she had killed Tabitha and led him to Tabitha’s burial site in the woods.
- After Graham’s arrest, Officer Matt Henderson testified that, during transport, Graham said Dixon was present and helped, and that Hartfield was at the house but not near where the killing occurred.
- Dixon later confessed to involvement and ultimately testified for the State.
- Graham was tried before Hartfield and was found guilty of murder and conspiracy. Hartfield’s trial occurred while Graham’s appeal was pending.
- Before Hartfield’s trial, Graham wrote a series of letters admitting she helped with Tabitha’s killing, giving details consistent with the autopsy, and stating Hartfield did not take part.
- At Hartfield’s trial, Graham invoked her Fifth Amendment privilege against self-incrimination and was unavailable to testify.
- Hartfield offered Graham’s letters to support his theory that Graham and Dixon committed the crime without him, and argued the letters were admissible as statements against penal interest by an unavailable declarant under Mississippi Rule of Evidence 804(b)(3).
- The trial court excluded the letters as hearsay. Hartfield was convicted of conspiracy to commit murder and appealed.

## Issues

1. Whether the trial court erred by excluding Graham’s letters, offered by Hartfield, when Graham was unavailable and the letters were arguably admissible as statements against penal interest under Mississippi Rule of Evidence 804(b)(3) with sufficient corroboration.
2. Whether excluding the letters denied Hartfield a meaningful opportunity to present his defense, requiring reversal of the conspiracy conviction.
3. Whether any error in excluding the letters was harmless.

## Decision

- The Mississippi Court of Appeals reversed Hartfield’s conspiracy conviction and remanded for a new trial.
- The court held Graham was unavailable because she invoked the Fifth Amendment at Hartfield’s trial while her appeal was pending.
- The court concluded the letters were strongly self-inculpatory, contained details matching independent evidence (including autopsy-consistent information), and were supported by circumstances showing reliability for purposes of Rule 804(b)(3) when offered to exculpate the accused.
- The court determined the exclusion prevented Hartfield from presenting evidence that directly supported his defense theory and was not harmless.

## Legal Principles

- A witness who invokes the Fifth Amendment privilege against self-incrimination may be treated as “unavailable” under Mississippi Rule of Evidence 804.
- Under Mississippi Rule of Evidence 804(b)(3), a statement is admissible if it so far tends to subject the declarant to criminal liability that a reasonable person would not have made it unless believing it true; when offered to exculpate the accused, the statement must be supported by corroborating circumstances that clearly indicate trustworthiness.
- Corroboration may be shown where the statement contains details consistent with independent evidence such as physical facts or forensic findings.
- A hearsay ruling may still require reversal when it blocks materially exculpatory evidence and denies the defendant a meaningful chance to present a defense.
- Exclusion of evidence tied to whether the defendant joined an agreement can be prejudicial in a conspiracy prosecution and may not be treated as harmless error.

## Conclusion

*Hartfield v. State* reversed a conspiracy-to-murder conviction because the trial court excluded an unavailable codefendant’s letters that admitted her own role in the killing, included autopsy-consistent details, and stated Hartfield did not participate; given the corroboration and the letters’ importance to Hartfield’s defense, the exclusion was reversible error and the case was remanded for a new trial.


Hartfield v. State, 168 So. 3d 1101 (2014)