Inferred Intent through Weapon Discharge and Reloading: Clarifying Attempted Murder Under Mississippi Law

Introduction

The Supreme Court of Mississippi’s decision in Damaris Quinn a/k/a Demaris Quinn a/k/a Demaris Q. Quinn v. State of Mississippi, No. 2024-KA-00195-SCT, dated April 24, 2025, addresses two pivotal issues in the realm of criminal law: the sufficiency of evidence to support an attempted murder conviction and the propriety of denying a requested jury instruction defining “murder” and “deliberate design.”

Appellant Quinn was convicted in the Clay County Circuit Court of attempted murder (Miss. Code Ann. § 97-1-7(2)) and of possession of a firearm by a convicted felon (Miss. Code Ann. § 97-37-5). On appeal, he challenged (1) the trial court’s refusal to grant jury instruction D-5, which defined the elements of murder and deliberate design, and (2) the legal sufficiency of the evidence supporting his attempted murder conviction. The Supreme Court affirmed both convictions, thereby underscoring key principles concerning inference of intent and the standards for jury instructions in criminal cases.

Summary of the Judgment

The Court affirmed the convictions and consecutive sentences imposed on Quinn—thirty-five years for attempted murder and five years for felon-in-possession.

The trial court’s denial of jury instruction D-5 was held within its discretion; jury instruction S-1, which tracked the elements of attempt under Brooks v. State, adequately conveyed the law.
Evidence—shooting the victim five times, reloading, and pursuing her—permitted a rational jury to infer the requisite intent to commit murder.
No reversible error was found in either the instruction ruling or the sufficiency of the evidence analysis.

Analysis

Precedents Cited

Victory v. State (83 So. 3d 370): Established that jury instructions are reviewed for abuse of discretion and must be considered as a whole.
Newell v. State (49 So. 3d 66): Held that a defendant is entitled to instructions presenting his theory of the case unless incorrect, duplicative, or unsupported by evidence.
Brooks v. State (18 So. 3d 833): Defined the elements of criminal attempt as intent, a direct ineffectual act, and failure to complete the crime.
Hughes v. State (983 So. 2d 270): Reinforced the Brooks framework and discussed inferences of intent from conduct.
Body v. State (318 So. 3d 1104) & Parish v. State (176 So. 3d 781): Articulated the Jackson v. Virginia sufficiency-of-the-evidence standard.
Hogan v. State (755 So. 2d 1073) & Rhodes v. State (676 So. 2d 275): Clarified viewing evidence in the light most favorable to the prosecution.
Thomas v. State (277 So. 3d 532): Confirmed that intent is a jury question and may be inferred from the totality of circumstances.
Fairchild v. State (459 So. 2d 793) & Shields v. State (244 Miss. 543): Longstanding authority that use of a deadly weapon permits an inference of malice or intent.

Legal Reasoning

On the jury-instruction issue, the Court emphasized that instruction S-1 accurately tracked the statutory language of Mississippi Code Section 97-1-7(2) and the Brooks test for attempt. Because S-1 fully and fairly presented the elements of attempted murder, including intent (“designed and endeavored to commit the murder”) and an overt act (“shooting Basheeba Ward multiple times”), the trial court did not abuse its discretion in refusing D-5.

Regarding evidentiary sufficiency, the Court applied the Jackson-standard: viewing all evidence favorably to the State and granting it all reasonable inferences. Quinn’s conduct—five gunshots to vital areas, reloading, and pursuing a fleeing victim—allowed a rational jury to conclude beyond a reasonable doubt that he intended to kill. Under longstanding precedent, the use of a deadly weapon and reloading mid-assault underscored a deliberate design to kill rather than merely to frighten or wound.

Impact

This decision reaffirms two significant principles:

Inference of Intent: A defendant’s intent to commit murder can be inferred not only from the initial discharge of a firearm but also from subsequent actions—especially reloading and pursuit—strengthening prosecutorial strategies in attempted murder cases.
Jury Instructions: Trial courts retain broad discretion to refuse redundant or partly inaccurate instructions; so long as the instructions given, taken together, accurately state the law and cover the defense theory, appellate courts will not find reversible error.

Future litigants should note the high bar for overturning convictions on instruction grounds and the emphasis on totality-of-circumstances inquiries into criminal intent.

Complex Concepts Simplified

Attempted Murder: A crime requiring (1) intent to kill, (2) an overt act toward killing, and (3) failure to complete the killing.
Deliberate Design: The conscious decision to kill another person, with no legal justification.
Directed Verdict (Motion for Judgment Notwithstanding the Verdict): A pre-closing argument motion asserting that the prosecution has not produced legally sufficient evidence on an essential element; denied here because a rational jury could infer intent.
Abuse of Discretion: An appellate standard that asks whether the trial court’s decision was arbitrary or unreasonable.

Conclusion

The Supreme Court of Mississippi’s affirmance in Quinn v. State clarifies that:

A jury may infer the specific intent to kill from multiple gunshots, reloading, and pursuit of a victim;
Jury instructions need only collectively and accurately state the law and may be denied if partly duplicative or unsupported by evidence;
Review of evidentiary sufficiency requires viewing all evidence in the light most favorable to the prosecution, with reasonable inferences drawn in its favor.

Together, these holdings reinforce prosecutorial and judicial approaches to attempted-murder prosecutions under Mississippi law and underscore the strategic importance of both evidence presentation and precise jury instructions.