Justia Mississippi Supreme Court Opinion Summaries

On July 9, 2022, Officer Cody Moulds of the Magee Police Department stopped Doyle Ray Middleton, Jr. for driving a motorcycle without a tag. Middleton, who only had a state ID card, consented to a search, and Officer Moulds found a bag containing a crystal-like substance. Middleton was issued tickets for an expired tag and misdemeanor possession of a controlled substance and was taken into custody. The substance was later determined to be a felony amount of narcotics.The Magee Municipal Court scheduled Middleton's court date for August 2, 2022, but he failed to appear. The court sent letters informing him of fines for the tickets and warned of a bench warrant if the fines were not paid. Middleton did not pay the fines, leading to a bench warrant and a notice of license suspension. On September 5, 2023, a Simpson County grand jury indicted Middleton for felony possession of methamphetamine. Middleton moved to dismiss the indictment, arguing double jeopardy, but the circuit court denied the motion, finding no prior conviction.The Supreme Court of Mississippi reviewed the case. Middleton argued that the municipal court's fine determination constituted a conviction, thus barring the felony indictment under double jeopardy. The State contended that the municipal court lacked jurisdiction over felony charges and that no conviction occurred. The court found no evidence of a conviction for misdemeanor possession in the municipal court, as the record only showed a fine determination and failure to appear, not a guilty disposition or fine payment.The Supreme Court of Mississippi held that Middleton had not been placed in double jeopardy because he failed to prove a prior conviction for the same offense. The court affirmed the trial court's denial of Middleton's motion to dismiss and remanded the case. View "Middleton v. State of Mississippi" on Justia Law

Staci Broome was convicted of aggravated assault after an altercation with Julie Mathis, the daughter of Broome's boyfriend, Michael Mathis. The incident occurred when Julie was at her father's house doing schoolwork, and Broome, upon learning of Julie's presence, confronted her. The confrontation escalated into a physical fight, during which Broome hit Julie with a metal object, causing significant injuries.The case was initially tried in the Simpson County Circuit Court, where the jury found Broome guilty of aggravated assault. Broome was sentenced to twenty years, with fifteen years to serve and five years of supervised probation. Broome appealed her conviction, arguing that the trial court erred by allowing hearsay testimony and lay opinion testimony on the ultimate issue.The Supreme Court of Mississippi reviewed the case. Broome contended that the trial court improperly admitted hearsay testimony from Investigator Brian Green, who testified about statements made by Julie Mathis during his investigation. The court found that Green's testimony about the metal object was not hearsay because it was offered to explain the steps he took during his investigation. Although the court acknowledged that Green's repetition of Julie's identification of Broome was hearsay, it deemed the error harmless given the overwhelming evidence against Broome.Broome also argued that the trial court erred by allowing Green to express his opinion on the ultimate issue of the case. The Supreme Court found that any error in admitting this testimony was harmless due to the substantial evidence presented by the State, including testimonies from Julie, Amber (Broome's daughter), and Michael, as well as physical evidence.The Supreme Court of Mississippi affirmed Broome's conviction and sentence. View "Broome v. State of Mississippi" on Justia Law

Lavern Kendrick was convicted in the Puckett, Mississippi, Municipal Court of misdemeanor driving under the influence (DUI), first offense, and possession of drug paraphernalia. The charges stemmed from a traffic stop at a safety checkpoint where officers observed a meth pipe in Kendrick's vehicle and detected the smell of methamphetamine. Kendrick admitted to possessing and recently using methamphetamine. He was arrested and convicted in municipal court.Kendrick appealed to the Rankin County County Court for a trial de novo, where he filed a motion to suppress the evidence, arguing that the traffic stop was unlawful. The county court denied the motion and found Kendrick guilty of both charges. The Rankin County Circuit Court affirmed the convictions on appeal.The Supreme Court of Mississippi reviewed the case, focusing on whether the safety checkpoint was constitutional. The court considered the testimony of the officers involved, who stated that the checkpoint's primary purpose was to check for driver's licenses and insurance. Despite some inconsistencies in the testimony of the less experienced officer, the court found that the checkpoint served a legitimate public interest and was not primarily for general crime control.The Supreme Court of Mississippi held that the safety checkpoint was permissible under the Fourth Amendment and the Mississippi Constitution, as it served a legitimate public interest and minimally intruded on individual liberty. The court affirmed Kendrick's misdemeanor convictions. View "Kendrick v. State of Mississippi" on Justia Law

Brandon J. Barnett was convicted of selling methamphetamine after a confidential informant, Kimberly Dido, arranged a controlled buy with him. Dido, who had previously bought drugs from Barnett, was working with the Jones County Sheriff’s Department in exchange for having her charges dropped. During the controlled buy, Dido was fitted with a hidden camera and given marked bills to purchase drugs from Barnett. The substance obtained was later confirmed to be 3.01 grams of methamphetamine.At trial, the forensic analyst who tested the substance did not testify. Instead, a different analyst, Charlotte Cothern, testified as a technical reviewer, stating that she agreed with the test results. Barnett’s counsel highlighted that Cothern did not personally test the substance. The trial court granted a jury instruction (Instruction S-3A) stating that it was permissible for a technical reviewer to testify in place of the primary analyst, which Barnett objected to, arguing it improperly commented on the weight of the evidence.The Mississippi Supreme Court reviewed the case and found that the trial court erred in giving Instruction S-3A. The court held that the instruction improperly commented on the weight and credibility of the technical reviewer’s testimony, which are matters for the jury to decide. The court emphasized that while the admissibility of the testimony is a legal question for the judge, the weight and credibility are exclusively for the jury. Consequently, the court reversed Barnett’s conviction and remanded the case for a new trial. View "Barnett v. State of Mississippi" on Justia Law

Olympia Williams was driving a Chrysler 200 on a public roadway with Mary Thomas as a passenger when they were struck by an ATV operated by Patricia Cole. The Chrysler 200, owned by Alonzo Johnson, was insured through Mississippi Farm Bureau Casualty Insurance Company (Farm Bureau) and included uninsured motorist coverage. Cole had no applicable insurance. Farm Bureau sought a declaratory judgment that it owed no uninsured motorist benefits, citing a policy exclusion for vehicles designed mainly for off-road use and not capable of being licensed for public roads.The Issaquena County Circuit Court granted summary judgment in favor of Farm Bureau, agreeing that the policy's exclusion applied to the ATV involved in the collision. Williams, Thomas, and Johnson argued that they were entitled to the full amount of the policy’s uninsured motorist coverage and that the exclusion unlawfully restricted coverage required by Mississippi’s Uninsured Motorist Act. They appealed the decision.The Supreme Court of Mississippi reviewed the case de novo and affirmed the circuit court's judgment. The court held that the policy's language was clear and unambiguous, excluding ATVs from the definition of "uninsured motor vehicle." The court also found that the exclusion did not unlawfully restrict or reduce coverage mandated by Mississippi’s Uninsured Motorist Act. The court concluded that the ATV operated by Cole did not qualify as an uninsured motor vehicle under the policy, and thus, Farm Bureau was not obligated to provide uninsured motorist benefits. View "Williams v. Mississippi Farm Bureau Casualty Insurance Company" on Justia Law

In this case, the appellant, X.G.C., appealed the termination of his parental rights over his child, V.I.C. The child was born in December 2019 and suffered multiple injuries while in the care of her parents, including a subdural hematoma and a fractured arm. The Jackson County Department of Child Protection Services (JCCPS) took custody of the child after determining that the injuries were consistent with abuse. Despite efforts to reunify the family, including a service plan and a ninety-day trial placement, the child sustained further injuries, leading to the termination of the father's parental rights.The Jackson County Youth Court initially placed the child in JCCPS custody and ordered efforts towards reunification. However, after the child sustained additional injuries during the trial placement with her father, the court changed the permanency plan to termination of parental rights. The court conducted multiple hearings and found that JCCPS had made reasonable efforts to assist the father in complying with the service plan, but he had failed to provide a safe environment for the child.The Supreme Court of Mississippi reviewed the case and affirmed the youth court's decision. The court found that the statutory requirements for termination under Mississippi Code Section 93-15-115 were met, including the adjudication of the child as abused, the child's placement in JCCPS custody for over six months, and the father's failure to comply with the service plan. The court also determined that termination was appropriate under Section 93-15-119, as the father's conduct demonstrated a substantial risk to the child's safety and welfare. The court concluded that the youth court's findings were supported by substantial evidence and that the termination of parental rights was in the best interest of the child. View "X.G.C. v. Jackson County Department of Child Protection Services" on Justia Law

Clover Boykin filed a lawsuit against Greenwood Leflore Hospital (GLH) under 42 U.S.C. § 1983, alleging that GLH intentionally withheld her medical records, preventing her from filing a medical malpractice suit. Boykin claimed that GLH's actions violated her constitutional right of access to the courts. GLH responded with a motion to dismiss, arguing that Boykin's claims failed as a matter of law, the employee was immune from suit, GLH was never served, and the suit was time-barred.The Leflore County Circuit Court denied GLH's motion to dismiss and granted Boykin additional time to serve GLH. GLH then sought an interlocutory appeal, which the Supreme Court of Mississippi granted. Boykin did not file a brief in response to the appeal.The Supreme Court of Mississippi accepted Boykin's failure to file a brief as a confession of error and found that Boykin's claims failed as a matter of law. The court held that HIPAA does not provide a private right of action and that Boykin could not use § 1983 to enforce a federal statute that does not give her an individual right. The court reversed the trial judge's denial of the motion to dismiss and rendered judgment in favor of GLH. View "Greenwood Leflore Hospital v. Boykin" on Justia Law

Judge Carlos Moore, a municipal court judge for the cities of Clarksdale and Grenada, faced allegations of misconduct related to his social media posts and public comments. The Mississippi Commission on Judicial Performance (the Commission) claimed that Moore's actions violated the Mississippi Constitution, the Code of Judicial Conduct, and a Memorandum of Understanding (MOU) between the Commission and Moore. The Commission's allegations stemmed from Moore's social media activity in 2021 and 2022, where he posted content that could be perceived as advertising his law practice and making racially charged comments.The Commission had previously warned Moore in 2019 about posting information on social media regarding cases he heard in court. In 2020, Moore and the Commission entered into an MOU, where Moore agreed to limit his social media posts to court-related information and not use his judicial title for personal or political purposes. Despite this agreement, Moore continued to post under the name "Judge Carlos Moore" and made public comments that the Commission deemed inappropriate.The Commission filed a Formal Complaint against Moore in July 2022, alleging violations of the Mississippi Constitution and the Code of Judicial Conduct. Moore did not respond to the complaint or participate in the Commission's proceedings. The Commission recommended Moore's removal from office, a six-year suspension, and a $5,000 fine.The Supreme Court of Mississippi reviewed the case and found that Moore's actions constituted willful misconduct and were prejudicial to the administration of justice. The Court held that Moore's comments on social media and television violated the judicial-conduct canons and the MOU. The Court ordered Moore's removal from the bench, a $3,000 fine, and assessed all costs. The Court emphasized that Moore's actions undermined public confidence in the judiciary and warranted a harsh sanction. View "Mississippi Commission on Judicial Performance v. Moore" on Justia Law

Jane's three young daughters were taken into custody by the Mississippi Department of Child Protection Services (CPS) due to unsafe living conditions and neglect. Jane had left her daughters with her disabled mother in a cramped, unsupervised apartment. CPS developed a service plan for Jane to regain custody, which included obtaining stable housing, employment, and transportation. Despite completing parenting classes and getting clean from drugs, Jane failed to comply with the other requirements. She did not secure stable housing or employment and did not regularly visit her daughters. Consequently, CPS petitioned to terminate her parental rights.The Monroe County Chancery Court held a termination hearing where CPS workers testified about Jane's noncompliance with the service plan and the unsafe conditions that led to the removal of her daughters. Jane testified about her efforts to get clean and find employment but admitted to various failures. The court-appointed Guardian Ad Litem recommended terminating Jane's parental rights, citing her unwillingness to provide for her daughters' basic needs. The chancellor found clear and convincing evidence supporting the termination based on statutory grounds, including abandonment, unwillingness to provide necessary care, failure to exercise reasonable visitation, and substantial erosion of the parent-child relationship.The Supreme Court of Mississippi reviewed the case and affirmed the chancellor's decision. The court held that substantial evidence supported the termination of Jane's parental rights, emphasizing that her lack of effort to care for and visit her daughters, rather than her lack of money, was the reason for the termination. The court found that the termination was in the best interest of the children to ensure a permanent and stable future. View "J.J.B. v. Monroe County Department of Child Protection Services" on Justia Law

Chester “Chet” Lake contested the probate of his mother’s will, which his sister Mary Chesnutt had filed. Lake doubted the will’s validity, claiming undue influence, and requested a jury trial to determine the issue of devisavit vel non. The Madison County Chancery Court entered a scheduling order but did not specify whether the trial would be a bench or jury trial. After the discovery and motions deadlines passed, Lake filed a Notice of Jury Trial. Chesnutt moved to strike the notice, arguing that Lake had waived his right to a jury trial by participating in pretrial proceedings and that the notice was untimely.The Madison County Chancery Court granted Chesnutt’s motion to strike, finding that Lake had waived his right to a jury trial by agreeing to the scheduling order and that his notice was untimely. Lake appealed this decision.The Supreme Court of Mississippi reviewed the case and held that Lake had not waived his right to a jury trial. The court found that under Mississippi Code Section 91-7-19, Lake was entitled to a jury trial upon request before any hearing on the issue of devisavit vel non. The court determined that the entry of the scheduling order did not constitute a hearing on the matter and that Lake’s notice, filed thirty-two days before the trial date, was timely. The court reversed the chancery court’s decision and remanded the case for further proceedings consistent with its opinion. View "In the Matter of the Estate of Lake v. Chesnutt" on Justia Law