Justices uphold body concealment conviction

November 24, 2018

HUNTINGTON - The West Virginia Supreme Court of Appeals has declined to overturn the conviction of a Huntington woman who hid a man’s body for days in her West Huntington hotel room after he died of an overdose.

Alfreda Jewell Steele, 49, was convicted by a jury in July 2017 of concealing the body of 36-year-old Bobby Mitchell for three days in a West Huntington motel room after Mitchell died of an apparent overdose. Cabell Circuit Judge Alfred E. Ferguson sentenced her to a one- to five-year prison sentence after her conviction.

The appeal restates arguments made and denied in Ferguson’s courtroom by attorneys James Meade and Robert Kuenzel, stating that the concealment statute is unconstitutionally vague and therefore Steele cannot be convicted of the crime.

The West Virginia statute regarding concealment of a deceased human body says, “Any person who, by any means, knowingly and willfully conceals, attempts to conceal ... a deceased human body where death occurred as a result of criminal activity is guilty of a felony.”

The defense attorneys argued the statute is unlawful because it does not define “criminal activity” and it also fails to “specify to what degree, if any, the accused must be involved in the criminal activity resulting in the death for it to constitute a violation of the statute.” As an example, a person hiding the body of someone who died of suicide was used.

The Supreme Court justices denied the appeal, pointing to a previous 2015 ruling in which it found the law to not be vague.

The case began Aug. 30, 2016, when first responders were called about an odor around the Coach’s Inn Motel in the 1000 block of Washington Avenue in West Huntington, where they uncovered Mitchell’s decomposing body wrapped in a hotel blanket at the foot of the room’s lone bed. His head was on the bed, his knees straddled the front left corner and his feet were on the floor.

Mitchell died a few days prior to the discovery of his body, after Steele claimed she injected him with heroin inside the room, according to criminal complaints from Cabell County Magistrate Court. Mitchell complained of feeling overheated before he, Steele and another man all lost consciousness on the room’s bed after injecting the drug, the complaint states.

Steele and the man awoke and realized Mitchell was not breathing, the complaint continues, and attempted CPR before realizing he had died. Mitchell’s body was then wrapped in a blanket and his death went unreported.

Neighbors began noticing the odor of decomposition coming from the room a few days later, and first responders were dispatched to investigate. After they found Mitchell’s body alone in the room, they stopped Steele on foot in the 600 block of 9th Street West a short time later after learning she had fled when she saw firefighters arriving on scene.

She was found guilty of the crime after just 30 minutes of jury deliberation.

According to the West Virginia Department of Corrections website, Steele is expected to be released in March 2019.

Follow reporter Courtney Hessler at Facebook.com/CHesslerHD and via Twitter @HesslerHD.

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