The Mississippi Court of Appeals on Thursday, Feb. 20, 2025 reversed the capital murder conviction of Carlos Roncali, ordering a new trial in the case involving the death of his wife, Marian Chaney Roncali.
The panel ruled that the trial court erred by allowing the forensic pathologist, Dr. Mark LeVaughn, to testify that Marian’s death was a homicide based largely on unverified information from law enforcement. The court concluded that the expert’s opinion was based on “unsupported speculation” rather than sufficient, reliable data.
Roncali, who had been convicted of capital murder and sentenced to life in prison without parole by a Newton County circuit court, had argued on appeal that the evidence presented at trial did not establish beyond a reasonable doubt that he was responsible for his wife’s death. In a lengthy opinion, the appellate judges noted that while there was sufficient evidence to support a conviction, the admission of Dr. LeVaughn’s testimony violated Mississippi’s evidentiary rules.
“Based on our review, the trial court abused its discretion in allowing testimony that was not supported by the necessary foundational facts,” the majority opinion stated. Authored by Judge Emfinger and joined by Judges Wilson, McCarty, and Weddle, the panel held that although sufficient evidence existed to support a conviction, the error in admitting Dr. LeVaughn’s testimony on the manner of death required reversing Roncali’s conviction and remanding the case for a new trial.
In contrast, Judge Carlton concurred in part—agreeing that the evidence could support a conviction—but dissented on the error regarding the expert testimony, effectively favoring an affirmation of Roncali’s conviction and sentence. Judge Westbrooks, dissenting separately, argued that the deficiencies in the evidence—particularly the failure to prove that a murder occurred during the course of a kidnapping—“warranted not just a remand but a complete reversal” of the conviction. Despite the dissenting view that the cumulative evidence was adequate to uphold Roncali’s conviction, the ruling remands the case back to the circuit court for further proceedings.
