Justia Mississippi Supreme Court Opinion Summaries

A police officer initiated a nighttime traffic stop in Madison, Mississippi, after noticing a vehicle with an unauthorized “PRIV4T3” license plate instead of a state-issued tag. The driver, Elizabeth Bozard, refused to provide identification and disregarded officers’ instructions not to leave the scene. She fled, leading multiple officers on a chase north and south on I-55, during which she ran a red light, passed vehicles on the shoulder, struck a police car, and drove over several spike strips before finally stopping. Bozard exited her vehicle and was arrested after officers subdued her. She was indicted for felony evasion and aggravated assault on a law enforcement officer.The case was tried before the Madison County Circuit Court, where Bozard testified in her own defense and the prosecution presented testimony from several officers, along with photographs and videos documenting the events. The jury acquitted Bozard of aggravated assault but convicted her of felony evasion. The trial court sentenced her to ten years in prison for the felony evasion conviction. Bozard appealed, raising only the issue of sufficiency of the evidence for her felony evasion conviction.The Supreme Court of Mississippi reviewed the case using a de novo standard for sufficiency of the evidence. Viewing the evidence in the light most favorable to the prosecution, the Court found that Bozard’s conduct—fleeing a traffic stop, leading officers on a prolonged chase, running a red light, passing vehicles unsafely, and striking a police car—demonstrated reckless or willful disregard for the safety of persons or property and extreme indifference to human life under Mississippi Code Section 97-9-72(2). The Court held that the evidence was sufficient to support the felony evasion conviction and affirmed both the conviction and sentence. View "Bozard v. State of Mississippi" on Justia Law

Daryl Moore was employed by the Coahoma County School District Board as an at-will assistant coach for the high school boys’ basketball team during the 2019-2020 and 2020-2021 school years. He was paid $1,500 per year for his assistant coaching duties. Moore claimed that, at the request of the athletic director, he also performed the duties of the head coach for the junior-high boys’ basketball team but was never compensated for those additional responsibilities. He asserted that he was entitled to $5,000 for serving as the junior-high head coach over two years and brought suit against the Board for unjust enrichment and underpayment.The County Court of Coahoma County reviewed Moore’s claims after he filed suit for unpaid compensation. The Board moved for summary judgment, relying on Mississippi’s “minutes rule,” which requires that any binding contract with a public board be reflected in the board’s official minutes. The court denied summary judgment, finding that factual disputes remained regarding Moore’s coaching roles and compensation, and granted Moore additional time for discovery. The Board appealed, and the Supreme Court of Mississippi granted interlocutory review under Mississippi Rule of Appellate Procedure 5.The Supreme Court of Mississippi held that Moore’s claims were barred by the minutes rule because there was no evidence in the Board’s minutes of any agreement to pay Moore as head coach or to increase his compensation. The Court found that, since the Board’s minutes did not reflect approval of additional pay for head-coaching duties, Moore could not recover under theories of quantum meruit or unjust enrichment. The Supreme Court reversed the county court’s decision and rendered summary judgment in favor of the Board. View "Coahoma County School District Board of Education v. Moore" on Justia Law

The case centers on the death of a two-year-old child, Hayden, who lived with his mother, Hailey, and her husband, Joseph. The family struggled financially, and Joseph was often home caring for Hayden while Hailey worked. On the morning of December 27, 2021, Hayden died after being repeatedly struck by Joseph and subsequently smothered by Hailey, according to Hailey’s testimony. Medical evidence indicated Hayden suffered extensive recent and past injuries consistent with ongoing physical abuse. Both Joseph and Hailey were indicted for capital murder. Hailey pleaded guilty to first-degree murder and received a life sentence, while Joseph pleaded not guilty and went to trial.The case was first tried in the Harrison County Circuit Court, Second Judicial District. A jury found Joseph guilty of capital murder and, after a penalty phase, unanimously sentenced him to death, finding he had attempted to kill Hayden and that the murder was committed during felonious child abuse and was especially heinous, atrocious, or cruel. Joseph’s post-trial motions for a new trial or judgment notwithstanding the verdict were denied.On direct appeal, the Supreme Court of Mississippi reviewed multiple claims of error, including the admission of expert and lay testimony, the exclusion of certain character evidence, the jury instructions regarding aggravating circumstances, the sufficiency of the evidence, and the proportionality and constitutionality of the death sentence. The Court applied heightened scrutiny due to the death penalty. It held that there was no reversible error in the admission of testimony, the aggravating circumstances were properly found, and the evidence was sufficient to support the jury’s findings. The Court affirmed Joseph’s conviction and death sentence, finding neither cumulative error nor constitutional infirmity. Claims of ineffective assistance of counsel were preserved for possible post-conviction relief but were not resolved on direct appeal. View "Heard v. State of Mississippi" on Justia Law

A woman experienced a difficult third pregnancy, complicated by multiple medical issues that warranted an early, medically induced labor. Before delivery, she signed a consent form authorizing her obstetrician to perform a vaginal delivery with possible laceration/episiotomy repairs and possible cesarean section. During labor, as the infant was crowning, she pleaded with her doctor not to perform an episiotomy, but the procedure was carried out. She later required reconstructive surgery due to complications from the episiotomy.She initiated legal action in the Hinds County Circuit Court against her obstetrician, the medical group, and other entities, alleging lack of informed consent and battery related to the episiotomy, along with other claims against additional defendants. Over time, the trial court issued a series of orders dismissing various claims and defendants, culminating in summary judgment for the obstetrician on the informed consent and battery claims, primarily due to the plaintiff’s failure to provide expert medical testimony. The plaintiff argued that expert testimony was unnecessary because she had withdrawn consent during labor, but the court disagreed.The Supreme Court of Mississippi reviewed the case. It held that while a medical procedure performed without consent may constitute battery and not require expert testimony, this scenario involved consent given prior to delivery and alleged withdrawal during labor. In such cases, it is necessary to prove that stopping the procedure was medically feasible and would not cause harm, which requires expert testimony. The Court affirmed the trial court’s summary judgment, finding that the plaintiff’s lack of expert evidence prevented her claims from proceeding, and upheld the trial court’s denial of reconsideration. View "Brown v. Davey-Sullivan" on Justia Law

A patient sought treatment at a state medical center for vision issues and was diagnosed with idiopathic intracranial hypertension. She initially chose medication over surgery but later agreed to undergo an optic-nerve sheath fenestration. Following continued vision decline, she received a shunt placement. Shortly after this procedure, she and her mother discussed concerns about her treatment, expressing suspicions that something had gone wrong and that she should seek care elsewhere. The patient continued follow-up visits at the center, but months later obtained a second medical opinion, which suggested prior care had been incorrect and provided an alternative diagnosis.The patient filed a notice of claim against the medical center more than a year after her suspicions of negligence but within a year of receiving the second opinion. She then filed suit for medical negligence. The University of Mississippi Medical Center moved for summary judgment in the Hinds County Circuit Court, arguing the claim was time barred under the Mississippi Tort Claims Act’s one-year statute of limitations. The trial court denied the motion, finding a genuine issue as to when the patient discovered the alleged negligence.The Supreme Court of Mississippi reviewed the denial of summary judgment de novo. It held that the statute of limitations began running when the patient first suspected negligent care, as shown by her own statements and those of her mother shortly after the shunt procedure, not when she received the second opinion. The court found no genuine issue of material fact that her suspicions triggered the limitations period, making her claim time barred. The court reversed the trial court’s decision and rendered summary judgment in favor of the medical center. View "University of Mississippi Medical Center v. Carter" on Justia Law

Mary Margaret Upchurch, who suffered from chronic back pain, underwent multiple surgeries involving spinal cord stimulators and pain pumps. In 2016, after moving to Mississippi, she had a pain pump replaced by Dr. Adam Lewis, a neurosurgeon at Jackson Neurosurgery Clinic. During surgery, Dr. Lewis attempted to replace the battery of her spinal cord stimulator with one from a different manufacturer, but encountered issues with the compatibility of the leads. This led to additional procedures, including a laminectomy and the eventual replacement of the stimulator, after which Mary experienced severe neurological complications, including paralysis. The Upchurches alleged that Dr. Lewis failed to properly prepare for surgery, did not obtain informed consent, and failed to communicate adequately with hospital staff.The case was tried in the Rankin County Circuit Court, where the jury found in favor of Dr. Lewis and Jackson Neurosurgery Clinic, concluding there was no negligence in Dr. Lewis’s care. The circuit court entered judgment on the jury’s verdict and denied the Upchurches’ motions for judgment notwithstanding the verdict and for a new trial. The Upchurches appealed, and the Mississippi Court of Appeals reversed the circuit court’s judgment, finding insufficient evidence supported the jury’s verdict and remanding the case for a new trial.The Supreme Court of Mississippi reviewed the case on certiorari. It held that the Upchurches’ failure to object to Dr. Lewis’s testimony at trial constituted waiver, and that his unobjected-to testimony should have been considered as evidence. The Court found sufficient evidence to support the jury’s verdict, reversed the Court of Appeals’ decision, and reinstated and affirmed the circuit court’s judgment in favor of Dr. Lewis and Jackson Neurosurgery Clinic. Additionally, the Court affirmed the circuit court’s order assessing appellate record costs against Dr. Lewis and the Clinic. View "Upchurch v. Lewis" on Justia Law

A dispute arose over real property in Harrison County, Mississippi, after the land was sold to the state for unpaid taxes in August 2017 and subsequently conveyed to Jermille Johnson via forfeited tax land patents in 2021. Elizabeth Cleveland, who had lived on the property since the 1980s, filed a complaint in the Harrison County Chancery Court seeking to quiet title through adverse possession and to void the tax sale due to lack of proper notice. Cleveland asserted that she had acquired ownership by adverse possession over more than twenty years.The Harrison County Chancery Court found that Cleveland had standing to challenge the tax sale and land patents, and determined the sale was void because the required notice had not been given. The chancellor cancelled the land patents and returned the property to the county. Johnson appealed, and the Mississippi Court of Appeals reversed the chancery court’s judgment, holding that Cleveland lacked standing to challenge the tax sale and that Mississippi Code Section 29-1-21 barred such claims once land was struck off to the state. The appellate court remanded the case for consideration of Johnson’s counterclaim to quiet title.On certiorari, the Supreme Court of Mississippi reviewed only the issue of Cleveland’s standing. The Court held that Cleveland has standing to challenge the tax sale because her adverse possession claim, if true, would have vested title in her by operation of law. Additionally, the unique facts of the case demonstrated an adverse impact sufficient to confer standing, as Cleveland faced losing her home. The Court rejected Johnson’s statutory argument, holding that other statutes permit challenges to tax sales. The Supreme Court of Mississippi reversed the Court of Appeals and reinstated and affirmed the judgment of the Harrison County Chancery Court. View "Johnson v. Cleveland" on Justia Law

A defendant was indicted as a habitual offender for one count of child exploitation after he sent sexually explicit messages via Facebook to a fourteen-year-old girl, I.R., in June 2023. The defendant, who was the father of I.R.’s cousin, had previously encountered I.R. at his daughter’s apartment complex and subsequently sent her a Facebook friend request. Messages from the defendant’s account included solicitations for sexual acts and offers of money. After receiving the messages, I.R. reported the incident to her mother and law enforcement. Investigators linked the defendant’s cell phone and Facebook activity to the time and place of the incident, and he made subsequent attempts to have the charges dropped in exchange for money.The case was tried in the Kemper County Circuit Court. During the trial, the prosecution introduced Facebook messages and cell phone records, including location data, all supported by certificates of authenticity. The defendant did not object to this evidence at trial. The jury found the defendant guilty, and the court sentenced him to life imprisonment as a habitual offender, based on prior convictions for aggravated assault and possession of cocaine with intent to distribute. The defendant’s motions for post-trial relief were denied.On appeal, the Supreme Court of Mississippi reviewed the case. The Court held that the defendant’s objections to the admissibility of evidence were procedurally barred due to failure to object at trial or pretrial, and the records were properly admitted as self-authenticating business records under Mississippi Rules of Evidence. The Court also found that the investigator’s testimony was permissible as lay opinion and did not require expert qualification. Additional claims—including mistake of fact, cruel and unusual punishment, and ineffective assistance of counsel—were found to be without merit or better suited for post-conviction proceedings. The Supreme Court of Mississippi affirmed the conviction and sentence. View "Rencher v. State of Mississippi" on Justia Law

Police officers arrested an individual after learning that two arrest warrants had been issued for him—one for shooting into a dwelling and another for possession of a firearm as a convicted felon. Upon arrest, officers conducted a pat-down search and discovered over two grams of methamphetamine in his pocket. Laboratory analysis confirmed the substance was methamphetamine. The defendant was indicted as a habitual offender for possession of methamphetamine.The Calhoun County Circuit Court presided over the jury trial in December 2024. Both officers involved testified about the circumstances of the arrest and the discovery of the drugs. The defense objected to the introduction of the warrant and later moved to dismiss the charge, arguing the defendant was not afforded a preliminary hearing after requesting one in justice court. The circuit court found no evidence of such a request and denied the motion. The defense also moved to suppress the warrants for lack of probable cause, but the court determined there was a substantial basis for probable cause, relying on the indictment and the justice court judge’s issuance of the warrants. The jury convicted the defendant of possession of methamphetamine and found him to be a habitual offender, resulting in an eight-year sentence. Post-trial motions for judgment notwithstanding the verdict or a new trial were denied.The Supreme Court of Mississippi reviewed the appeal. Applying a mixed standard of review to the Fourth Amendment issues, the Court held that the circuit court had a substantial basis for determining probable cause existed when the warrants were issued. It found the warrants met procedural requirements and that officers verified their existence. The conviction and sentence were affirmed. View "Eacholes v. State of Mississippi" on Justia Law

In 2019, a man was indicted in Coahoma County, Mississippi, on three charges: sexual battery of a child under fourteen, felonious child abuse, and exposing another to HIV. The case involved his eight-year-old daughter, who moved to live with him that year. After the child disclosed abuse to her older sister, she was taken to the hospital, where injuries consistent with sexual abuse were observed. Medical professionals and law enforcement became involved, and the child underwent further examinations and interviews. During the investigation, the defendant admitted to law enforcement that he was HIV positive.A jury in the Coahoma County Circuit Court found the defendant guilty on all three counts. The trial court sentenced him to twenty years for sexual battery, and five years each for child abuse and exposing another to HIV, all to be served concurrently. The defendant’s motion for a new trial was denied. On appeal to the Supreme Court of Mississippi, the defendant challenged only his conviction for exposing another to HIV, arguing the trial court violated his Confrontation Clause rights by admitting Mississippi Department of Health records without the opportunity to cross-examine their custodian and that the State presented insufficient evidence of knowing exposure.The Supreme Court of Mississippi held that the Confrontation Clause argument was procedurally barred because it was not raised at trial and, alternatively, the admitted records were non-testimonial business records not subject to the Confrontation Clause. The court also determined that the State had presented sufficient evidence for a rational juror to convict under the plain language of the statute, which required proof that the defendant was HIV positive and knowingly exposed the child. The conviction and sentence were affirmed. View "Sims v. State of Mississippi" on Justia Law