Justia Mississippi Supreme Court Opinion Summaries

R.W. and J.R. are the biological parents of twins Rachel and Joshua, born prematurely on May 9, 2022. Both R.W. and the twins tested positive for amphetamines at birth. The Jackson County Youth Court placed the children in the custody of the Mississippi Department of Child Protection Services (CPS) and later adjudicated them as neglected children. The court also ruled that CPS could bypass reasonable efforts to reunify the twins with their parents. R.W. and J.R. appealed this decision.The Jackson County Youth Court initially held an emergency custody hearing, followed by an adjudication hearing where the twins were declared neglected. The court found that R.W. had a history of substance abuse and had previously lost custody of her other children. J.R. was incarcerated for failing to register as a sex offender. The court ruled that CPS could bypass efforts to reunify the children with their parents due to the parents' history and current circumstances. R.W. and J.R. raised issues on appeal regarding jurisdiction, venue, and the sufficiency of evidence supporting the neglect adjudication and the bypass of reunification efforts.The Supreme Court of Mississippi reviewed the case and affirmed the youth court's judgment. The court held that the youth court had both subject-matter and personal jurisdiction, and that Jackson County was the proper venue. The evidence presented, including the positive drug tests and the parents' histories, was sufficient to support the adjudication of neglect. The court also found that bypassing reasonable efforts to reunify the children with their parents was justified based on the parents' past terminations of parental rights and J.R.'s criminal history. The Supreme Court of Mississippi affirmed the youth court's decision. View "R.W. v. Mississippi Department of Child Protection Services" on Justia Law

The Mississippi Public Service Commission (the Commission) authorized a rate increase for Entergy Mississippi, LLC (Entergy) based on a joint stipulation with the Mississippi Public Utilities Staff (the Staff). Rankin County, an Entergy customer, intervened, disputing the exclusion of unbilled revenue from Entergy’s operating expenses. The Commission found substantial evidence supporting the rate increase and deemed new issues raised by Rankin County on appeal as waived.Rankin County intervened in the Commission’s proceedings, challenging the exclusion of unbilled revenue from Entergy’s operating income. The Commission held a public hearing, but Rankin County did not present admissible evidence. The Commission approved the rate changes, including an Annual Rate Adjustment and an Interim Rate Adjustment, based on Entergy’s financial data and the Formula Rate Plan. Rankin County appealed directly to the Supreme Court of Mississippi without seeking rehearing from the Commission.The Supreme Court of Mississippi affirmed the Commission’s order, finding that the exclusion of unbilled revenue was reasonable and supported by substantial evidence. The court held that Rankin County waived new issues raised on appeal by not presenting them to the Commission. The court also found no merit in Rankin County’s arguments regarding the recalculation of net rate adjustments, the application of the 4 percent cap on revenue increases, and the management of Entergy’s confidential records. The Commission’s order was affirmed as it complied with statutory and regulatory procedures, and the rate adjustments were not arbitrary or capricious. View "Rankin County, Mississippi v. Mississippi Public Service Commission" on Justia Law

Lucas Montel Howard, while detained in the Madison County jail, directed his friend Alissia Washington to purchase crack cocaine from a dealer. Law enforcement monitored their phone calls, and when Washington returned with the drugs, she was pulled over and instructed by Howard to hide the cocaine in her vagina. The drugs were later discovered during a search at the police department, leading to Howard and Washington’s indictment on felony drug charges. Washington entered a best-interest plea, while Howard went to trial and was found guilty of possession of cocaine with intent to sell and conspiracy to possess cocaine with intent to sell.The Madison County Circuit Court sentenced Howard as a nonviolent habitual offender and subsequent drug offender to sixty years for possession with intent to sell and twenty years for conspiracy, to run concurrently. Howard appealed, arguing insufficient evidence of intent to sell, a Confrontation Clause violation, double jeopardy, improper admission of Washington’s guilty plea, prosecutorial misconduct, ineffective assistance of counsel, and a sleeping juror issue.The Supreme Court of Mississippi reviewed the case and found that the evidence, including Howard’s phone calls and prior convictions, sufficiently supported the jury’s findings of intent to sell and conspiracy. The court held that the trial court did not abuse its discretion in limiting cross-examination or in handling the sleeping juror issue. The court also found no merit in Howard’s claims of double jeopardy, prosecutorial misconduct, or ineffective assistance of counsel. The cumulative error doctrine was deemed inapplicable as no errors were identified. Consequently, the Supreme Court of Mississippi affirmed Howard’s convictions and sentences. View "Howard v. State of Mississippi" on Justia Law

In June 2016, an explosion damaged a gas processing plant in Moss Point, owned by Enterprise Gas Processing LLC. Enterprise alleged that the explosion was caused by Hetsco Inc.'s negligent repair of a heat exchanger. Hetsco argued that a Proposal for Services between it and the plant's prior owner, BP, entitled it to summary judgment. The circuit court agreed, granting summary judgment in favor of Hetsco.The Jackson County Circuit Court found that BP's employee, Hayes, had apparent authority to bind BP to the Proposal for Services, which included a forum-selection clause and a two-year statute of limitations. The court concluded that the Proposal for Services was a valid and enforceable contract, and thus, Enterprise's claims were barred by the forum-selection clause and the statute of limitations.The Supreme Court of Mississippi reviewed the case and found that genuine issues of material fact remained regarding Hayes's apparent authority to bind BP to the Proposal for Services. The court noted that the evidence did not conclusively show that Hayes had the authority to agree to the legal terms of the Proposal for Services. Additionally, the court found that there were factual disputes about whether BP ratified the Proposal for Services and whether Enterprise could be bound by it as BP's successor.The Supreme Court of Mississippi reversed the circuit court's grant of summary judgment and remanded the case for further proceedings. The court held that the contractually shortened two-year statute of limitations in the Proposal for Services was unenforceable under Mississippi law. The court did not address the enforceability of the forum-selection clause, leaving that issue for the circuit court to consider on remand. View "ACE American Insurance Company v. Hetsco, Inc." on Justia Law

In the early morning of April 29, 2020, Davonta Wells went to his former girlfriend Taharika Smith's home and, after being denied entry, fired six shots into the residence. Wells was identified as the shooter by Smith, a guest named James Rice, and a neighbor, Pierre Beard. Wells was charged with shooting into an occupied dwelling and possession of a firearm by a convicted felon. He was tried by a jury in the Circuit Court of Lowndes County, Mississippi, and convicted on both counts. Wells was sentenced as a nonviolent habitual offender to ten years for shooting into an occupied dwelling and ten years with four years suspended for possession of a firearm by a convicted felon, to run consecutively.Wells appealed, arguing that the evidence was insufficient to support his conviction for possession of a firearm by a convicted felon because the stipulation of his prior felony was not formally admitted into evidence. The State contended that Wells waived this argument by not objecting at trial and that the stipulation, along with a limiting jury instruction, was sufficient.The Supreme Court of Mississippi reviewed the case and found that Wells was procedurally barred from raising the issue for the first time on appeal. The court also applied the invited error doctrine, noting that Wells had made a tactical decision to stipulate to his prior felony conviction and did not object at trial. The court declined to adopt Wells's proposed requirement for written stipulations to be admitted into evidence, affirming that the current law, which allows for stipulations to be presented through jury instructions, was sufficient. The court held that the stipulation and the limiting instruction provided to the jury met the evidentiary requirements, thus affirming Wells's conviction for possession of a firearm by a convicted felon. View "Wells v. State of Mississippi" on Justia Law

Laquon Fluker was convicted of conspiracy to commit aggravated assault. The incident involved Fluker and others allegedly attacking James Bryant in a prison cell, resulting in Bryant being stabbed. Fluker requested a jury instruction on the lesser-included offense of conspiracy to commit simple assault, which the trial court denied. The jury found Fluker not guilty of aggravated assault but guilty of conspiracy to commit aggravated assault.The Forrest County Circuit Court denied Fluker's request for the lesser-included-offense instruction. The Court of Appeals affirmed this decision, reasoning that the presence of shanks and the nature of the attack indicated an intent to commit aggravated assault. The appellate court held that the evidence did not support a finding of negligence, which would be necessary for a simple assault instruction.The Supreme Court of Mississippi reviewed the case on certiorari. The court found that the trial court erred in denying the lesser-included-offense instruction. The Supreme Court held that, based on the testimony of a co-conspirator, a reasonable jury could have found Fluker guilty of conspiracy to commit simple assault rather than aggravated assault. The court emphasized that the jury should have been allowed to consider whether the agreement among the conspirators was to commit simple assault. Consequently, the Supreme Court reversed the judgments of the Court of Appeals and the Forrest County Circuit Court and remanded the case for a new trial. View "Fluker v. State" on Justia Law

David Archie contested the results of the Hinds County Supervisor primary runoff election held on August 8, 2023, alleging election irregularities. He filed a petition for judicial review on September 8, 2023, one day past the statutory deadline. The key issue on appeal was whether the Hinds County Circuit Clerk’s office was open or closed on September 7, 2023, as the deadline would be extended if the office was closed.The Hinds County Circuit Court dismissed Archie’s petition, finding it was filed outside the allowable time period. The court based its decision on the fact that the courthouse was open on September 7, 2023, but did not make specific findings about whether the clerk’s office was open or closed.The Supreme Court of Mississippi reviewed the case and found that the evidence was insufficient to determine whether the clerk’s office was open or closed on September 7, 2023. The court noted that while the courthouse was open, the clerk’s office doors were locked, and there was conflicting evidence about whether the office was accessible for conducting business. The court vacated the circuit court’s judgment and remanded the case for a more thorough evidentiary hearing to determine the status of the clerk’s office on the critical date.The main holding by the Supreme Court of Mississippi was that the circuit court’s judgment was vacated and the case was remanded for further proceedings to establish whether the clerk’s office was open or closed on September 7, 2023, which would affect the timeliness of Archie’s petition. View "Archie v. Smith" on Justia Law

In 1998, Michael Johnson, then 17, conspired with Aaron Johnson to murder Aaron’s roommate, Dustin Sean Parker. They planned the murder for hours, eventually deciding to bludgeon Parker to death with a metal barbell. After killing Parker, they wrapped his body in plastic bags and buried it in the woods. Johnson later bragged about the murder, leading to his arrest and conviction for deliberate-design murder. He was sentenced to life in prison without the possibility of parole.The Rankin County Circuit Court initially sentenced Johnson to life without parole. Following the U.S. Supreme Court's decision in Miller v. Alabama, which deemed mandatory life-without-parole sentences for juveniles unconstitutional, Johnson sought post-conviction relief. The trial court vacated his sentence and held a new hearing, considering the Miller factors. Despite this, the court reinstated Johnson’s life sentence, ruling that the parole statute's application was not unconstitutional.The Supreme Court of Mississippi reviewed the case. Johnson argued that the trial court misapplied the law and facts and that Mississippi Code Section 99-19-101 required jury sentencing for juveniles. The court found that recent statutory amendments did not entitle Johnson to jury sentencing, as he was convicted before July 1, 2024. The court also upheld the trial court's application of the Miller factors, noting Johnson’s age, the premeditated nature of the crime, and the lack of evidence suggesting his immaturity or inability to understand the consequences of his actions. The court affirmed the trial court’s decision, maintaining Johnson’s life sentence without parole. View "Johnson v. State" on Justia Law

Derrick Chatman was convicted of two counts of sexual battery by a jury in the Adams County Circuit Court. The jury was also instructed on the lesser-included offense of gratification of lust for both counts. Chatman appealed, arguing that the jury’s verdict was ambiguous and not fully responsive to the verdict forms, which included the lesser-included offense. He claimed the trial court erred by not directing the jury to retire for further deliberations.The Adams County Circuit Court sentenced Chatman to thirty years for each count, with fifteen years suspended and fifteen years to serve consecutively. Chatman filed a motion for judgment notwithstanding the verdict or, alternatively, for a new trial, which the trial court denied. On appeal, Chatman raised the issue of the ambiguous verdict for the first time, arguing that the trial court should have directed the jury to deliberate further under Mississippi Rule of Criminal Procedure 24.3.The Supreme Court of Mississippi reviewed the case and agreed that the jury’s verdict was ambiguous regarding the sexual battery charges. The court found that the trial court should have directed the jury to retire for further deliberations. The court noted that the jury’s general verdicts of guilty did not clarify whether they found Chatman guilty of sexual battery or the lesser-included offense of gratification of lust. Consequently, the court reversed Chatman’s convictions for sexual battery.The Supreme Court of Mississippi reversed and remanded the case for either a new trial on the sexual battery charges or for resentencing on two counts of gratification of lust, at the option of the State. The court emphasized that the ambiguity in the jury’s verdict required this remedy to ensure a fair and just outcome. View "Chatman v. State of Mississippi" on Justia Law

Soweto Ronnell Love pled guilty to two counts of attempting to acquire or obtain possession of a controlled substance by forged prescription and was sentenced as a habitual offender to five years on each count, to run consecutively. Love later filed a pro se Motion for Post-Conviction Collateral Relief (PCR), challenging the voluntariness of his guilty plea. The Tate County Circuit Court dismissed his PCR motion without an evidentiary hearing, finding that Love's plea was voluntary based on the record.On appeal, the Mississippi Court of Appeals affirmed the circuit court's dismissal of Love's PCR motion in a divided decision. The Court of Appeals held that a factual basis existed for Love's plea and that he failed to show his plea was involuntary. Love then filed a pro se motion for rehearing, which was denied, and subsequently filed a petition for writ of certiorari, which the Supreme Court of Mississippi granted.The Supreme Court of Mississippi found that the circuit court erred in dismissing Love's PCR motion without an evidentiary hearing. The court held that Love was misinformed about the minimum penalty he faced as a habitual offender, which amounted to a misapplication of the law and plain error. The court also found that the record did not confirm that Love knowingly pled guilty as a habitual offender. Consequently, the Supreme Court reversed the circuit court's dismissal of Love's PCR motion and the Court of Appeals' decision, remanding the case to the circuit court for an evidentiary hearing to determine whether Love voluntarily pled guilty as a habitual offender. View "Love v. State of Mississippi" on Justia Law