Can a jury determine guilt based solely on the word of a crack addict?
Mariah Eckler buries her head under a blanket and covers her ears to drown out the fear she hears in her mother’s voice, which comes in dribs, drabs and the occasional scream from another room.
It’s about 2 a.m., 5 days before Christmas in 2012. The 12-year-old is experiencing an event she’s likely never to forget in a house on a dead-end road called Memory Lane usually so calm an unlocked front door is common.
Her ordeal would become an example of just how difficult it is to define one of the most relied upon yet least understood legal principles in America’s criminal justice system.
But it wouldn’t be her ordeal alone. Willie Dean Whaley, who was 90 years old the night of the crime, is suffering, too. She had been reliant upon her grandson, Jamar Huggins, for round-the-clock care for at least two years.
Huggins is the man who was charged with the home invasion. As his arrest, incarceration and trial played out, his children’s grades in school and their eating habits would also be affected.
“Ain’t no way Jamar is guilty. But you got to have a test to have a testimony,” Whaley said of her grandson’s journey through the justice system. “He’s gonna have a testimony after this.”
Just what constitutes guilt beyond a reasonable doubt? In this case, there was no hard evidence, the primary witness and detective admitted lying, the judge considered dismissing the charges, the prosecution and defense scrambled to change strategies midstream — and still the jury handed down a verdict that baffled even an alternate juror?
The past few years have seen numerous calls for criminal justice reform, fueled by state leaders’ attempts to get a better hold of their budgets and revelations made by groups such as the Innocence Project, which has helped free hundreds of men falsely imprisoned.
The push for reform has intensified during the 2016 presidential election cycle. Democratic and Republican candidates such as Hillary Clinton and Rand Paul have made it part of their platforms. Barack Obama recently became the first sitting U.S. president to visit a prison to highlight the issue.
But one of the system’s bedrocks, perhaps its glue, the beyond a reasonable doubt standard, has not emerged as a target for reform even though it is a shell of its former self. That standard shapes the system more than false confessions, mistaken eyewitness accounts, the emergence of DNA technology and mandatory minimum sentencing requirements.
“What exactly is proof ‘beyond a reasonable doubt?’ Anyone who has served as a criminal juror knows that the rule is not easy to understand. There is always some possible uncertainty about the case. Exactly what kind of uncertainty counts as a legal ‘doubt?’ Exactly when are legal ‘doubts’ about the guilt of the accused ‘reasonable’?” James Q. Whitman of Yale Law School wrote in “Origins of Reasonable Doubt.” “Even some of the most sophisticated members of the legal profession find the question too difficult to answer. The result is troubling indeed. Once a jury has determined a person to be guilty ‘beyond a reasonable doubt,’ that person’s fate is almost always sealed.”
While many believe the standard grew out of a legal foundation, it began as something else entirely.
“Jurors had to fear vengeance on the part of the relatives of the convicted men,” Whitman wrote. “But it was also for religious reasons. Convicting an innocent defendant was regarded, in the other Christian tradition, as a potential mortal sin. The reasonable doubt rule developed in response to this disquieting possibility. It was originally a theological doctrine, intended to reassure jurors that they could convict the defendant without risking their own salvation.”
Neuroscientific research suggests that there is folly in trying to determine a single “reasonable” standard. The race of the defendant and victim, racial makeup of the jury, the camera angle of videos shown during a trial, the influence of police lineups and a host of other factors color how an individual juror decides between guilty and not guilty, even when the juror is trying to be objective.
Subtle phrasing of sentences, how a defendant is dressed and his mannerisms also impact trial outcomes.
“Jurors and judges can’t help but be influenced by their backgrounds and experiences. The laws and facts are filtered through the lens of our identities,” said Adam Benforado, author of “Unfair: The New Science of Criminal Injustice.” “Even when juries are given guidance as to the meaning of ‘beyond a reasonable doubt,’ we can’t ensure the consistency in application that we promise. ... It appears that some of the worst racial bias in our system occurs because of implicit biases that operate beyond people’s conscious awareness or control.”
During deliberations, the strength of a lone juror’s personality may end up being more important than the evidence being weighed.
It’s also why millions of Americans were convinced that the verdict in the high-profile O.J. Simpson murder case was reasonable — while millions of others thought it was a travesty. The revelation that a primary detective in the case was known for using the n-word and bragging about routinely violating the constitutional rights of defendants, coupled with the mishandling of key evidence, was enough to justify a not guilty verdict even if they strongly suspected Simpson had murdered two people, some believed.
Others thought such factors were not enough to override what they saw as overwhelming evidence of guilt, as well as a lack of a plausible alternatives.
Each side is convinced it reached its final judgment based on a reasonable, objective analysis of the facts.
Which conclusion was most reasonable in the legal sense? Only the jury’s — no matter how they arrived at it.
“All this means that it is no surprise that our law finds itself in a state of confusion today,” Whitman wrote. “We are asking the reasonable doubt standard to serve a function that it was not originally designed to serve.”
Holiday calm, then a storm
A few hours before Mariah Eckler’s ordeal began, the 12-year-old had helped her mother, Angela Eckler, set up a Christmas tree and decorations bought as a surprise by a family friend. The pair then cuddled together on the bed to watch “Elf,” a movie about the surreal experience of a toddler accidentally taken to the North Pole and raised as one of Santa’s helpers.
Instead of being involved in a silly fantasy like the Will Ferrell character, Mariah Eckler soon found herself in the middle of an ugly reality.
Two men, one in a dark mask and dark gloves, rushed through the front door of her home and put her mother in a chokehold so tight bruises on her neck would last for weeks. They dragged her by the hair through a living room whose darkness was broken only by glare from the TV and tea lights in the window.
Angela Eckler was bounced into the side of her grandfather’s rocking chair before one of the men stuck a gun in her face demanding “the [expletive] money.”
There’s no doubt something awful happened to the Ecklers. The question was who did it and why.
About a month after the break-in, Huggins was charged with first degree burglary, armed robbery and kidnapping. He went to trial almost two years later. Including jury selection, it lasted three days.
Though neither of the Ecklers could identify the men who attacked them, there was no hard evidence linking Huggins to the crime — and the main witness had told multiple, contradictory versions of the same story — by the end of the trial, there was no reasonable doubt he was involved, at least in the minds of 12 jurors, the prosecutor, the judge, the police detective who investigated the case, and the victims.
After the verdict, a portion of a victim impact statement by Mariah Eckler was read aloud in the courtroom by the prosecutor before Judge Benjamin H. Culbertson handed down a sentence.
“I saw a man with a gun, Jamar Huggins, then the other guy that was with him ask me, ‘Where’s the money?’” the statement read. “I thought for sure Jamar was going to shoot my mom.”
Culbertson sentenced Huggins to concurrent 15- and 10-year prison sentences for first degree burglary, armed robbery and kidnapping.
But given that it was dark, the man with the gun wore a mask and the entire case against Huggins hinged solely on the credibility of a woman who was addicted to crack cocaine, from where did such certainty come?
The investigation begins
Horry County Detective Jonathan Martin sat in the house that several hours earlier had been the scene of a home invasion. Two men, one masked and wielding a gun, forced their way in and didn’t leave until the Ecklers had been trapped in a bathroom, where they would remain until they were sure the men had left.
Cases like these are often doled out in the violent crimes unit of the Horry County Police Department based upon level of seriousness and “solvability.”
Martin, in his first year as a detective after climbing through the ranks of the department for at least five years, was also investigating three murders and other crimes for a department that has seen a high level of turnover the past several years and in a unit in which each detective is investigating about 25 violent crimes simultaneously.
He began with the victim, Angela Eckler, where he discovered a hint of a motive that would drive his investigation and become a key during Huggins’s trial.
Eckler had never heard of Huggins. She didn’t recognize Huggins when later shown a photo.
Three other key pieces of information emerged during Martin’s talks with Eckler:
1) She could not identify the second man who forced himself into her home.
2) She could ID the “pretty black woman” who knocked on her front door to begin the break-in.
3) None of the physical evidence Martin collected placed Huggins in the house.
About 14 months before the home invasion, Eckler’s former middle school classmate, Adrian Moore, moved from Nebraska to marry her after they had reconnected through a year-long Facebook-based relationship.
“He was active with my kids,” Eckler told Martin. “We never went out; we never had any drinks. That’s not what we did.”
There were no signs Moore was “being into mischief.”
But Moore had difficulty finding a job. He was trying to advance his academic career and Eckler figured finding steady work hours that would accommodate his studies wouldn’t be easy.
Moore offered to take over paying the bills, with income Eckler earned through a babysitting business.
The couple set up a joint checking account. Initially, Moore did as he said he would, paid the bills, deposited checks and kept the couple’s finances seemingly on track. But in the weeks leading up to the break-in, things had begun to change.
Moore claimed he had found occasional hourly, on-call work and had been using Eckler’s Ford Expedition. One Monday he received an extra shift, he told Eckler, and didn’t return home until the following morning.
A couple of weeks before the break-in, Moore was scheduled to take an important test at Coastal Carolina University. About the same time, Eckler received a call from her bank, wondering if her card had been stolen.
Her account had been overdrawn by a couple thousand dollars.
“There were multiple uses on his card, and they put a hold on it,” Eckler said.
She frantically began calling Moore. He didn’t return her voicemail or text messages.
On the afternoon of the home invasion, a man in a car with a malfunctioning driver’s side door showed up at Eckler’s home asking for a man named Drake.
She had never heard of a man named Drake, not realizing he was the same man she’d been planning to marry.
Contact Issac J. Bailey at @ijbailey via Twitter.com.
This story was originally published September 16, 2015 at 2:52 PM with the headline "Can a jury determine guilt based solely on the word of a crack addict?."