Following a jury trial, Shameka Hall was found guilty of attempted capital murder and sentenced to 40 years in prison. The conviction stemmed from a plot to have her stepbrother kill her ex-boyfriend’s new girlfriend. Hall appealed the conviction, arguing that the evidence presented at trial was insufficient and that the jury’s verdict went against the weight of the evidence. However, the Mississippi Court of Appeals has upheld the original ruling, finding no errors in the trial.
The Facts of the Case
The case began in October 2022 when Hall texted her stepbrother, Bernardo Loftin, to discuss something “ASAP.” A meeting was arranged, and Hall asked Loftin to kill Ariunna Myers, who was in a relationship with Hall’s ex-boyfriend, Donnell Wright. Over the following days, Hall and Loftin exchanged numerous texts and discussed the details of the plan.
Loftin, however, became concerned that he was being set up. He contacted his probation officer, who then put him in touch with detectives from the Hattiesburg Police Department (HPD). The detectives asked Loftin to secretly record his conversations with Hall. Loftin agreed and used a hidden camera provided by the police to record a meeting with Hall. During this meeting, Hall reiterated her desire for Myers to be killed, and they agreed on a price of $2,000, with a $200 down payment. Hall also promised to provide Loftin with a gun. As Loftin was driving Hall back to work, police officers stopped the car and arrested Hall.
At trial, Loftin testified that Hall had a clear motive: she wanted Myers “out of her life” and wanted Wright back. He also testified to the detailed planning that took place, including discussions of how and when the murder would occur. The video recording of the conversation between Hall and Loftin was played for the jury. In the video, Hall appeared adamant about the plan, stating that she had created a fake Facebook account to track Myers and her location. Hall also provided Loftin with information about Myers’s whereabouts.
Another witness, Manessa Decker, testified that Hall had threatened to kill Myers previously.
Hall’s defense was that her conversations with Loftin were not about a murder plot but rather about hiring him to make repairs to a house. She claimed she was going through a “mental break” due to financial stress and homelessness.
The Court’s Analysis: Sufficiency of the Evidence
Hall argued that the State did not provide enough evidence to support her conviction. She claimed that the evidence showed only “planning” or a “possible design” to commit murder, not an actual attempt.
The appeals court reviewed the case *de novo*, meaning they reviewed it as if it were a new case. The court explained that, in cases of attempted murder, the law in Mississippi does not require proof of an overt act. The court cited a 2013 amendment to the attempt statute that specifically removed the overt act requirement for attempted murder. The court found that the state had to prove Hall “design[ed] and endeavor[ed] to commit an act which, if accomplished, would constitute an offense of [capital] murder.”
The court then looked to a previous case, *Stokes v. State* (1908), which established that the intent to commit a crime, plus any slight act toward its consummation, is sufficient to constitute an attempted crime. In *Stokes*, the defendant had hired someone to kill another person and was arrested while in the process of handing over a gun.
The court found that Hall’s actions went beyond mere planning. They noted Hall’s repeated insistence that she wanted Myers killed, her agreement to pay Loftin, her promise to provide a gun, and her advice to Loftin on how to carry out the murder. The court concluded that these actions, taken together, were enough to prove an attempt under the law.
The Court’s Analysis: Weight of the Evidence
Hall also argued that the jury’s verdict was against the weight of the evidence. The appeals court stated that it would only overturn a verdict if it was so contrary to the evidence that it would be an “unconscionable injustice” to let it stand. The court found that the jury’s verdict was supported by the evidence and affirmed the lower court’s decision.
The court stated that the jury was free to weigh and assess the credibility of Hall’s testimony. The court found that Hall’s testimony did not overwhelm the proof of her guilt.