When reviewing the sufficiency of the evidence, we must ask "whether, viewing the evidence in the light most favorable to the State and giving the State the benefit of all favorable inferences reasonably drawn from the evidence, any rational juror could have found the essential elements of the crime beyond a reasonable doubt." Chisholm v. State, 365 So. 3d 229, 245 (¶66) (Miss. 2023). For the reasons addressed below, we are not persuaded by Moates’s assertions and find that the evidence presented was sufficient to allow a reasonable juror to find that Moates committed simple domestic violence in this case.
¶23. "This Court reviews whether a Brady violation occurred de novo." Douglas v. State, 378 So.3d 361, 374 (¶ 42) (Miss. 2024) (internal quotation marks omitted) (quoting Chisholm v. State, 365 So.3d 229, 242 (Miss. 2023)). To prove a Brady violation, the defendant must establish:
When reviewing the sufficiency of the evidence, we determine "whether, viewing the evidence in the light most favorable to the State and giving the State the benefit of all favorable inferences reasonably drawn from the evidence, any rational juror could have found the essential elements of the crime beyond a reasonable doubt." Chisholm v. State, 365 So. 3d 229, 245 (Miss. 2023) (citing Williams v. State, 285 So. 3d 156, 159 (Miss. 2019)). For weight-of-the-evidence challenges, we view the evidence in the light most favorable to the jury’s verdict.
"This Court reviews whether a Brady violation occurred de novo." Chisholm v. State, 365 So. 3d 229, 242 (Miss. 2023) (citing Thomas v. State, 45 So. 3d 1217, 1219 (Miss. Ct. App. 2010)). "Under Brady v. Maryland, ‘suppression by the prosecution of evidence favorable to an accused upon request violates due process where the evidence is material either to guilt or to punishment, irrespective of the good faith or bad faith of the prosecution.’
¶40. The trial court acts "as gatekeeper on questions of admissibility of expert testimony." See Chisholm v. State, 365 So.3d 229, 24 (¶43) (Miss. 2023). In discussing the trial court's role as "gatekeeper," this Court recently described the process to be used to determine the admissibility of expert testimony at trial and the standard of review of an appellate court in Howell v. State, No. 2023-KM-00265-COA, 2024 WL 3872637, at *4-5 (¶¶15-16) (Miss. Ct. App. Aug. 20, 2024), reh'g denied (Jan. 7, 2025):
Whether a Brady violation occurred is reviewed de novo. Chisholm v. State, 365 So. 3d 229, 242 (¶51) (Miss. 2023). Establishing a Brady violation requires a defendant to show:
¶27. When reviewing the sufficiency of the evidence, this Court "view[s] the evidence in the light most favorable to the State and giv[es] the State the benefit of all favorable inferences reasonably drawn from the evidence" to determine whether "any rational juror could have found the essential elements of the crime beyond a reasonable doubt." Chisholm v. State, 365 So.3d 229, 245 (¶66) (Miss. 2023).
¶58. Turning to the merits, when reviewing a sufficiency-of-the-evidence argument, we ask whether, after "viewing the evidence in the light most favorable to the State and giving the State the benefit of all favorable inferences reasonably drawn from the evidence, any rational juror could have found the essential elements of the crime beyond a reasonable doubt." Chisholm v. State, 365 So.3d 229, 245 (¶66) (Miss. 2023) (citing Williams v. State, 285 So.3d 156, 159 (Miss. 2019); Martin v. State, 214 So.3d 217, 222 (Miss. 2017); Hughes v. State, 983 So.2d 270, 276 (Miss. 2008)). We are not required to decide-and in fact, we must refrain from deciding-whether we think the State proved the elements. Rather, we must decide whether a reasonable juror could rationally say that the State did.
¶19. Whether a Brady violation occurred is reviewed de novo. Chisholm v. State, 365 So.3d 229, 242 (¶51) (Miss. 2023). Establishing a Brady violation requires a defendant to show:
"The test for sufficiency of the evidence is whether, viewing the evidence in the light most favorable to the State and giving the State the benefit of all favorable inferences reasonably drawn from the evidence, any rational juror could have found the essential elements of the crime beyond a reasonable doubt." Chisholm v. State, 365 So. 3d 229, 245 (¶66) (Miss. 2023). "[A]ll credible evidence [that] is consistent with guilt must be accepted as true …."