## Facts

- James C. Newell, Jr. went to the Slab House bar parking lot in Lowndes County, Mississippi, looking for his wife and a suspected romantic rival.
- Newell saw his wife’s truck and encountered Adrian Boyette near it; an argument followed, and Newell walked back toward his own truck.
- Boyette followed Newell to the truck and, under Newell’s account, yelled threats, beat on the truck, and slammed the truck door on Newell’s leg.
- Newell testified that after he got into the truck, Boyette continued threatening to pull him out and harm him.
- Newell opened the truck door and exited; he testified Boyette threatened to “cut” him and reached toward his pocket.
- Newell retrieved a pistol from the truck and shot Boyette, who later died from the gunshot wound.
- Newell was charged with and convicted of manslaughter in the Lowndes County Circuit Court.
- At trial, the court excluded Boyette’s toxicology report offered by the defense and refused Newell’s requested jury instruction on the amended Castle Doctrine’s presumption of reasonable fear as applied to an occupied vehicle.

## Issues

1. Whether excluding the victim’s toxicology report was reversible error where the defense claimed it was relevant to the victim’s aggressiveness and the defendant’s self-defense theory.
2. Whether the trial court erred by refusing a requested jury instruction on the amended Castle Doctrine presumption of reasonable fear and related self-defense protections for an occupied vehicle, where evidence supported the instruction.

## Decision

- The Mississippi Supreme Court reversed the manslaughter conviction and remanded for a new trial.
- The court held the trial court committed reversible error by excluding the victim’s toxicology report because it was relevant to the self-defense claim and not harmless in a case turning on reasonableness and perceived threat.
- The court held the trial court also erred by refusing a properly supported Castle Doctrine instruction, which prevented the jury from considering the statutory presumption and no-duty-to-retreat framework under the defendant’s version of events.

## Legal Principles

- A defendant is entitled to jury instructions that correctly state the law and are supported by evidence, even if the evidence is disputed.
- Evidence bearing on the victim’s condition and behavior may be admissible when it helps the jury evaluate a self-defense claim, including the reasonableness of the defendant’s fear and the events surrounding the confrontation.
- Mississippi’s amended Castle Doctrine provides, under specified conditions, a statutory presumption that the defender reasonably feared imminent death or great bodily harm when facing unlawful, forcible entry or an attempt to remove an occupant from an occupied vehicle, and it removes any duty to retreat when the defender is lawfully present and not engaged in unlawful activity.
- Errors affecting the jury’s ability to consider a supported self-defense theory and relevant proof are reversible when they are not harmless in light of the central disputed issues at trial.

## Conclusion

The court ordered a new trial because excluding relevant toxicology evidence and denying a supported Castle Doctrine presumption instruction materially impaired the jury’s evaluation of Newell’s self-defense claim in a case focused on the victim’s alleged aggression and the reasonableness of Newell’s fear while in or at his truck.


Newell v. State, 49 So. 3d 66 (Miss. 2010)