The Trials of C-Murder: How A Jim Crow Law Lead to Rapper’s Life Imprisonment and Why He May Soon Be Released
Corey Miller, better known to hip-hop fans as “C-Murder,” is currently serving a life sentence in the Louisiana State Penitentiary for the fatal shooting of 16-year-old Steve Thomas in 2002. While a stage name like “C-Murder” probably didn’t bode well for one defending a murder charge, neither did a Louisiana law with origins in Jim Crow. Now, due to a recent decision in the U.S. Supreme Court, Miller may finally have a shot at freedom.
Miller, the younger brother of hip-hop mogul Percy “Master P” Miller, first rose to fame in the late 1990’s as an artist on his brother’s New Orleans based record label “No Limit Records.” Miller’s life as he knew it, came to a screeching halt on January 12, 2002, when someone opened fire after a fight broke out in a crowded nightclub in Harvey, Louisiana. 16-year-old Steve Thomas, was struck once in the chest and later died from his injuries.
Despite little to no physical evidence linking Miller to the crime, Miller was arrested and charged with Thomas’ murder. In 2003, Miller was found guilty, but was quickly granted a new trial after prosecutors failed to disclose information regarding the criminal backgrounds of a number of witnesses who testified against Miller.
In 2009, Miller was retried and found guilty of second-degree murder in large part due to testimony from two eye-witnesses and a peculiar Jim Crow-era law that allowed defendants to be convicted despite a prosecutor failing to obtain a unanimous jury verdict. In Miller’s case, 10 out of 12 jurors voted to find him guilty. In all other U.S. states, with the exception of Oregon, if all jurors could not agree on a verdict, a hung jury would result, leading to a mistrial. In 2018, Louisiana voted to amend its constitution to require unanimous jury verdicts. However, the amendment was not retroactive and thus, those who were actually harmed by the law did not reap the benefits of its revision.
Throughout this ordeal, Miller maintained his innocence and spent the next 10 years fighting to overturn his conviction — amongst other things — on the grounds that the U.S Constitution requires a unanimous verdict for criminal convictions. Unfortunately for Miller, the judges did not agree and denied appeal after appeal. Miller even applied to the United States Supreme Court, who declined to hear the case.
Although there were obvious setbacks, not everything went wrong for Miller’s case. Two key witnesses who testified against Miller at trial recanted their testimony identifying Miller as the shooter in sworn affidavits. The witnesses claim pressure from police caused them to falsely identify Miller as Thomas’ shooter. ‘Reasonable Doubt,’ a true-crime television series, investigated Miller’s case and raised doubts about his guilt. Miller’s brother, Master P, used his media influence to raise awareness about the case and even held public rallies calling for his brother’s release. Miller himself argued his case through his art, releasing songs like “Dear Supreme Court,” where he raps about “forced verdicts” and the injustice of his conviction.
Miller’s latest attempt at freedom, a Motion for Post-Conviction Relief, partly based on witness recantations, was denied last year after a judge found that the recantations were not credible. However, a recent Supreme Court decision, may finally carve a pathway to Miller’s freedom. In April 2020, the U.S. Supreme Court issued a decision in Ramos v. Louisiana, holding that convictions based on split jury verdicts are unconstitutional in state criminal cases. In delivering the opinion, Justice Gorsuch did not mince words about the racist origins and intent behind Louisiana’s split verdict law:
Though it’s hard to say why these laws persist, their origins are clear. . . Seeking to avoid unwanted national attention, and aware that this Court would strike down any policy of overt discrimination against African-American jurors as a violation of the Fourteenth Amendment, the delegates sought to undermine African-American participation on juries in another way. With a careful eye on racial demographics, the convention delegates sculpted a “facially race-neutral” rule permitting 10-to-2 verdicts in order “to ensure that African-American juror service would be meaningless.”
It’s unclear whether prosecutors will pursue a third, and most likely weaker, version of an already flimsy case against Miller. What is clear, is that the Supreme Court’s ruling is likely to impact not only Corey Miller’s case, but countless others like Cardell Hayes, who was convicted of murdering former NFL player Will Smith by a 10–2 split verdict in 2016. Hayes has already requested a new trial based upon the Supreme Court’s decision in Ramos and with Louisiana, long bearing the title of the global leader in imprisonment, many similar requests are sure to follow.
Disclaimer: This article is not a substitute for professional legal advice. The information provided in this article does not, and is not intended to, constitute legal advice; instead, all information, content, and materials provided are for general educational purposes only and to discuss the potential effects of changes in law.