Justia Mississippi Supreme Court Opinion Summaries

Tony Clark was convicted of capital murder, attempted murder, and possession of a firearm by a previously convicted felon. His death sentence was affirmed by the Mississippi Supreme Court, and the United States Supreme Court denied his petition for writ of certiorari. Clark subsequently filed his first motion for post-conviction relief, claiming intellectual disability and ineffective assistance of counsel, among other issues.The Madison County Circuit Court initially reviewed the case, and the Mississippi Supreme Court affirmed Clark's convictions and sentence. Clark then sought post-conviction relief, which led to the current appeal.The Supreme Court of Mississippi reviewed Clark's motion for post-conviction relief. The court granted the motion in part, remanding the case to the Madison County Circuit Court for an Atkins hearing to determine if Clark is intellectually disabled, which would make him ineligible for execution under the Eighth Amendment. The court found that Clark presented sufficient evidence, including affidavits from medical professionals, to warrant a hearing on his intellectual disability claim. However, the court denied all other claims, including ineffective assistance of counsel related to mitigation evidence, Batson challenges, jury wheel issues, the avoiding arrest aggravator, jurors' racial bias, and jury instructions. The court also rejected Clark's cumulative error argument. The decision was to grant post-conviction relief in part and deny it in part. View "Clark v. State" on Justia Law

Joanne Pearson, a Republican candidate for Madison County Election Commissioner in District Three, won the election against Walter Young, Jr., a Democratic candidate, by a vote of 5,772 to 3,917. Pearson had filed her application to qualify as a candidate in January 2024, and the Madison County Board of Supervisors approved her candidacy in February 2024. Five citizens, collectively referred to as Brown, appealed the Board’s decision, arguing that Pearson’s application was incomplete and that there was a conflict of interest with the Board’s attorney, Spence Flatgard.The Madison County Circuit Court reviewed the case and denied Brown’s motion to disqualify Flatgard, affirming the Board’s decision to approve Pearson’s candidacy. The court found that Pearson’s application, despite some incomplete areas, met the statutory requirements for the position. Brown then appealed both decisions to the Supreme Court of Mississippi.The Supreme Court of Mississippi reviewed the case and affirmed the lower court’s decisions. The court held that the Board did not act arbitrarily or capriciously in approving Pearson’s candidacy. It found that Pearson’s application substantially complied with the statutory requirements, and any minor irregularities did not mislead the electors. The court also upheld the circuit court’s decision to deny the motion to disqualify Flatgard, finding no conflict of interest as the Board and the election commission were not adverse parties in this matter. The court concluded that the Board’s decision was supported by substantial evidence and was within its discretionary power. View "Brown v. Madison County Board of Supervisors" on Justia Law

Mercedes B. Clark was stopped by Officer Ricky Robinson for speeding and driving on the wrong side of the road. During the stop, Officer Robinson smelled burnt marijuana and conducted a DUI investigation. A search of Clark's vehicle revealed a clutch bag containing a half-smoked marijuana joint, multicolored pills, and items with Clark's name. Clark admitted the bag was hers but claimed a male acquaintance had put his belongings in it, which she thought was marijuana.A Lauderdale County jury found Clark guilty of trafficking eutylone, a Schedule I controlled substance. The trial court sentenced her to ten years without parole. Clark's appellate counsel filed a brief under Lindsey v. State, stating no arguable issues for appeal. Clark filed a pro se supplemental brief raising three issues: the exclusion of her after-arrest interview, improper jury instructions, and a request for parole eligibility for first-time offenders.The Supreme Court of Mississippi reviewed the case. The court found that Clark had agreed to the exclusion of her interview with Agent Wilburn, making her argument on this point meritless. The court also determined that the jury instructions were proper, as they required the jury to find that Clark "unlawfully, wilfully, and feloniously" possessed the eutylone, which implicitly included the requirement of knowing possession. Lastly, the court noted that it does not have the authority to amend statutes, thus denying Clark's request for parole eligibility.The Supreme Court of Mississippi affirmed Clark's conviction and sentence, finding no arguable issues warranting relief. View "Clark v. State of Mississippi" on Justia Law

Promenade D’Iberville, LLC, the owner and developer of a large retail shopping center in D’Iberville, Mississippi, discovered soil issues during construction in 2009. The problems were linked to the use of OPF42, a soil stabilizer containing bed ash from Jacksonville Electric Authority (JEA), a Florida public utility. Promenade filed a lawsuit in 2010 in the Harrison County Circuit Court against several parties, including JEA, alleging damages from the defective product.The Harrison County Circuit Court granted JEA’s motion to dismiss for lack of subject-matter jurisdiction, citing sovereign immunity based on California Franchise Tax Board v. Hyatt (Hyatt III). The court also held that the Full Faith and Credit Clause and comity principles required dismissal due to Florida’s presuit notice and venue requirements. Promenade appealed the decision.The Supreme Court of Mississippi reviewed the case and found that Hyatt III does not apply to JEA, as it is not an arm of the State of Florida but an instrumentality of the City of Jacksonville. The court also determined that neither the Full Faith and Credit Clause nor comity principles mandated dismissal. The court held that Promenade should be allowed to proceed with its claims against JEA in Mississippi, seeking damages similar to those allowed under Mississippi’s constitution for property damage.The Supreme Court of Mississippi reversed the trial court’s judgment of dismissal and remanded the case for further proceedings consistent with its opinion. View "The Promenade D'Iberville, LLC v. Jacksonville Electric Authority" on Justia Law

A man was charged with six counts of statutory rape involving his eleven-year-old daughter, who lived with him after her mother was incarcerated. The daughter testified that her father raped her on multiple occasions, providing detailed accounts of the assaults. Evidence included her birth certificate, which established both her and her father’s ages, and testimony from family members and investigators. The defendant denied the allegations, suggesting the accusations were fabricated due to disciplinary issues.The Circuit Court of Yazoo County conducted a jury trial, during which the defendant’s counsel submitted jury instructions that omitted the statutory requirement that the defendant be at least twenty-four months older than the victim. The State agreed to use the defense’s instructions. The jury convicted the defendant on all counts, and he was sentenced to thirty years’ imprisonment. On appeal, the Mississippi Court of Appeals reversed the conviction, holding that the omission of the age-gap element from the jury instructions constituted reversible error.The Supreme Court of Mississippi reviewed the case on certiorari. It held that, under the invited-error doctrine, a defendant cannot complain on appeal about an error in jury instructions that he himself requested and received. The Court found that the defendant was estopped from challenging the omission of the age-gap element, as he had submitted the instructions and the State and trial court had accepted them. The Court also rejected the defendant’s other claims, including ineffective assistance of counsel, sufficiency of the evidence regarding venue, improper admission of hearsay, and a Batson challenge. The Supreme Court of Mississippi reversed the Court of Appeals’ decision and reinstated and affirmed the conviction and sentence imposed by the Circuit Court of Yazoo County. View "Allen v. State" on Justia Law

Lea and Ann Brent were married in 1953 and divorced in 1983. As part of their divorce, Lea agreed to pay Ann $5,600 per month in permanent periodic alimony until her death or remarriage. Ann died in 2015, never having remarried. Lea began paying less than the required amount in 2002, but Ann never filed a contempt action for the unpaid alimony. Lea died in 2021, and Ann’s Estate filed a probate claim against Lea’s Estate for unpaid alimony totaling $358,700, covering the period from 2002 to 2015.The Washington County Chancery Court found that the claim for unpaid alimony was valid but limited it to the period from July 2014 to November 2015 due to the seven-year statute of limitations. The court awarded Ann’s Estate $139,104, which included the unpaid alimony for that period plus 8 percent interest per annum. However, the court denied Lea’s Estate credit for partial alimony payments totaling $51,000 made between July 2014 and November 2015 and for a $75,143.28 life insurance proceeds payment made to Ann’s Estate in 2019.The Supreme Court of Mississippi reviewed the case and found that the chancery court erred in denying Lea’s Estate credit for the partial alimony payments and the life insurance proceeds payment. The Supreme Court held that the total amount of credit exceeded the total amount owed for the relevant period, leaving no unpaid alimony to award Ann’s Estate. Consequently, the Supreme Court reversed the chancery court’s decision and rendered judgment in favor of Lea’s Estate. View "In re The Estate of Brent v. The Estate of Brent" on Justia Law

In October 2019, April Jones and Will Polk were reported missing. The investigation stalled until 2021 when Keith Coleman, Jr. confessed to shooting and dismembering them. Coleman was indicted on two counts of first-degree murder and two counts of desecration of a corpse. At trial, Coleman claimed his girlfriend, Chelsea Golden, was the actual shooter, and he had previously confessed to protect her. The jury found Coleman guilty on all counts, and he was sentenced to two consecutive life terms for the murders and three years for each desecration count, to run concurrently.Coleman appealed his convictions, arguing that the verdict was against the overwhelming weight of the evidence. He claimed his confession was coerced to protect Golden and that the State's witnesses were unreliable. The Mississippi Supreme Court reviewed the case, noting that the jury is responsible for resolving conflicts in testimony and determining witness credibility. The court found that the jury had ample testimonial evidence to support the verdict, despite the lack of physical evidence directly linking Coleman to the crime.The Mississippi Supreme Court held that the jury's verdict was not against the overwhelming weight of the evidence and affirmed Coleman's convictions. The court emphasized that issues of witness credibility and conflicting testimony are for the jury to resolve, and the absence of physical evidence does not negate a conviction when there is sufficient testimonial evidence. View "Coleman v. State of Mississippi" on Justia Law

Numerous plaintiffs filed claims against a law firm and its attorneys who represented them in mass-tort actions. The plaintiffs alleged mishandling and improper distribution of settlement funds obtained from these actions. After years of litigation and jurisdictional conflicts, the cases were brought before the Rankin County Circuit Court.The circuit court referred the cases to a special master who conducted hearings on various motions, including plaintiffs' motions to consolidate, defendants' motions to sever, and defendants' motions to re-open discovery. The special master recommended granting the plaintiffs' motions to consolidate and denying the defendants' motions to sever and re-open discovery. The circuit court adopted these recommendations by order on February 27, 2023. Defendants sought interlocutory appeals on all four cases, which were granted.The Supreme Court of Mississippi reviewed the case and affirmed the decisions of the Rankin County Circuit Court. The court held that the plaintiffs' claims met the requirements for joinder of parties under Rule 20 and consolidation of cases under Rule 42. The court found that the claims arose from a distinct chain of events involving the same defendants, the same mass-tort litigation, and the same settlement funds. The court also determined that consolidating the cases would further judicial economy without prejudicing any party. Additionally, the court upheld the denial of defendants' motions to re-open discovery, noting that the litigation had been pending for years with no restrictions on discovery and much of the requested discovery had already been obtained. The case was remanded to the Rankin County Circuit Court for further proceedings. View "Freese v. Estate of Alford" on Justia Law

Christopher Doby was shot on August 23, 2019, at South Park Village Apartments in Laurel, Mississippi. Christopher and Cheyveon Doby filed a lawsuit against South Park Village Apartments, its management company, Millennia Housing Management, and its owners, South Park MS, LLC, and South Park MS Investment, LLC. The complaint alleged that South Park failed to maintain the premises in a reasonably safe condition, provide adequate security, repair or maintain fences, gates, and locks, and warn tenants and guests of dangerous conditions. It also claimed that South Park knew or should have known of prior criminal acts on the property and failed to take reasonable measures to prevent future criminal activity.The Jones County Circuit Court dismissed the complaint under Mississippi Rule of Civil Procedure 12(b)(6), finding that the complaint alleged only general negligence and did not contain allegations that South Park affirmatively impelled the third party’s conduct. The court also dismissed Cheyveon Doby’s claims, noting that the complaint made no specific allegations concerning him. The Dobys filed a motion for reconsideration, which the trial court denied, leading to the current appeal.The Supreme Court of Mississippi reviewed the case de novo and held that the allegations in the complaint, taken as true, were sufficient to state a claim for relief under Mississippi’s notice pleading standard. The court found that the complaint provided reasonable notice of the claims against South Park and demonstrated a recognized cause of action upon which Christopher Doby might prevail. However, the court affirmed the dismissal of Cheyveon Doby’s claims due to the lack of specific allegations pertaining to him. Consequently, the Supreme Court of Mississippi affirmed in part, reversed in part, and remanded the case for further proceedings regarding Christopher Doby’s claims. View "Doby v. South Park Village Apartments" on Justia Law

William H. Tatum Jr. was convicted of bank fraud and had a $15,284,348 restitution judgment against him. He owned a 50% membership interest in Tatum Land and Cattle Company, LLC (TLCC). Upon his death in 2018, his estate, including his TLCC interest, was left to his wife, Betsy Gay Roberts-Tatum. Betsy died in 2020, and her son, Zachary I. Haynie, became the executor of her estate. Darrell Tatum, William’s grandson, was appointed executor of William’s estate. The United States, Peoples Bank, and John Deere Financial filed claims against William’s estate.The Tippah County Chancery Court admitted William’s will to probate and appointed Gay as executrix. After Gay’s death, Darrell was appointed as successor executor. Darrell petitioned for the public sale of William’s TLCC interest to satisfy estate debts. Zach opposed, seeking to enforce the TLCC operating agreement’s buyout provision. The chancellor ordered the public sale, which resulted in Joe Tatum purchasing the interest for $675,000. Zach objected, arguing the sale price was inadequate and sought relief, including assignment of the promissory note and deed of trust from Peoples Bank.The Supreme Court of Mississippi reviewed the case. The court found that any additional funds recovered from the estate would go to the United States due to the restitution judgment, rendering Zach’s claims moot. The court dismissed the appeal as moot, noting that a decision would not benefit Zach practically since the United States would claim any additional funds. The court affirmed the chancellor’s decisions, including the public sale and denial of Zach’s motions. View "In The Matter of The Estate Tatum" on Justia Law