Justia Mississippi Supreme Court Opinion Summaries

Mark Lovil, the manager of R.K. Metals, LLC, signed a commercial lease with E&E, Co. Inc. in 2015 in his representative capacity. The lease did not include a personal guaranty or arbitration clause. R.K. Metals became delinquent in rent payments, leading E&E to require a new lease in 2018, which included both a personal guaranty and an arbitration clause. Lovil signed the new lease as president of R.K. Metals, but R.K. Metals claimed they were unaware of the new clauses until the final version was delivered.R.K. Metals filed a complaint in the Lee County Circuit Court in May 2020, seeking declaratory relief and asserting breach-of-contract claims. The circuit court found the lease enforceable and ordered arbitration. E&E sought to include Lovil personally in the arbitration, leading to a determination of his status as guarantor. The circuit court granted E&E’s Motion for Summary Judgment, finding Lovil personally liable as guarantor and a necessary party to arbitration.The Supreme Court of Mississippi reviewed the case de novo. The court held that Lovil’s signature on the lease, despite his corporate designation, bound him personally as guarantor due to the clear language of the guaranty clause. The court also found that Lovil, as personal guarantor, was bound by the arbitration clause. The court applied the doctrine of equitable estoppel, noting Lovil’s close legal relationship with R.K. Metals, and concluded that he must participate in arbitration.The Supreme Court of Mississippi affirmed the circuit court’s judgment, holding that Lovil is personally bound as guarantor and compelled to participate in arbitration. View "R.K. Metals, LLC v. E & E Co., Inc." on Justia Law

In 2012, the victim's mother rekindled a relationship with Cayce William Jones and moved into his house with her two children. After moving in, Jones sexually battered the victim. A grand jury indicted Jones on one count of sexual battery and one count of fondling. A Monroe County jury convicted Jones on both counts.Jones appealed, arguing that he received ineffective assistance of counsel because his trial counsel failed to file post-trial motions. The Monroe County Circuit Court handled the initial trial and conviction.The Supreme Court of Mississippi reviewed the case. Jones contended that his trial counsel was constitutionally ineffective for not filing a motion for a new trial. The court noted that ineffective-assistance-of-counsel claims are sometimes better suited for post-conviction relief proceedings but can be addressed on direct appeal if the record affirmatively shows ineffectiveness or if the parties stipulate that the record is adequate. The court found that the record showed Jones's claim was without merit and addressed it on direct appeal.The court applied the Strickland v. Washington standard, which requires showing that counsel's performance was deficient and that this deficiency prejudiced the defense. Jones failed to demonstrate a reasonable probability that a motion for a new trial would have succeeded. The court noted that the evidence against Jones, including the victim's testimony and expert testimony, countered his arguments. The court concluded that the trial involved conflicting testimony, which the jury properly resolved.The Supreme Court of Mississippi affirmed Jones's conviction and sentence, finding that he did not show that his counsel's decision not to file a motion for a new trial prejudiced his defense. View "Jones v. State of Mississippi" on Justia Law

Zachary Minor was charged with possession of marijuana and trafficking of THC after a package containing these substances was delivered to a residence in Natchez, Mississippi. Agents from the Mississippi Bureau of Narcotics observed the delivery and arrested Mario Hartwell, who retrieved the package. Minor was found in the truck with Hartwell, and evidence from Minor's phone linked him to the package. A grand jury indicted Minor and Hartwell on multiple counts, and Minor's trial was severed from Hartwell's.The Adams County Circuit Court conducted a jury trial, during which the State made several errors, including commenting on Minor's right to remain silent, eliciting inflammatory testimony about the effects of edibles on children, and introducing hearsay evidence from Hartwell. The jury found Minor guilty of possession with intent to distribute and trafficking THC. Minor's motions for a mistrial and a new trial were denied, and he was sentenced to concurrent terms of ten and twenty years.The Court of Appeals affirmed Minor's conviction, finding that the errors were either waived or harmless. However, a dissenting opinion argued that the cumulative effect of the errors warranted a new trial. Minor then petitioned for certiorari.The Supreme Court of Mississippi reviewed the case and found that the cumulative effect of the errors deprived Minor of a fair trial. The court held that the State's actions, including commenting on Minor's right to remain silent, eliciting prejudicial testimony, and introducing inadmissible hearsay, constituted prosecutorial misconduct. The court reversed the Court of Appeals' decision and remanded the case to the circuit court for a new trial. View "Minor v. State of Mississippi" on Justia Law

Shanta Webster filed a complaint in the Grenada County Circuit Court against the University of Mississippi Medical Center-Grenada (UMMC-Grenada) and Drs. Aimee Watts and Kimberly Farmer, alleging medical negligence in the performance of a hysterectomy and post-operative care. Webster served the complaint to Dr. Watts, Dr. Farmer, and Dodie McElmurry, the CEO of UMMC-Grenada. The defendants requested an extension to answer the complaint and later claimed immunity under the Mississippi Tort Claims Act (MTCA). Webster argued that service of process was proper under Rule 4(d)(8) of the Mississippi Rules of Civil Procedure.The Grenada County Circuit Court dismissed the complaint, ruling that service of process was improper because it was not made to the Attorney General as required by Rule 4(d)(5) for state institutions. Webster appealed the dismissal, maintaining that UMMC-Grenada is a community hospital and that service on the CEO was sufficient.The Supreme Court of Mississippi reviewed the case de novo and upheld the trial court's decision. The court found that UMMC-Grenada is not a separate entity but a part of UMMC, a state institution. Therefore, service of process should have been made to the Attorney General under Rule 4(d)(5). Webster failed to serve the Attorney General within the 120-day period required by Rule 4(h), rendering the service invalid. Additionally, the court noted that Drs. Watts and Farmer, acting within the scope of their employment, were immune from personal liability under the MTCA.The Supreme Court of Mississippi affirmed the trial court's order of dismissal, concluding that proper service of process was not effected, and the individual defendants were immune from liability. View "Webster v. University of Mississippi Medical Center Grenada" on Justia Law

Linda Lee owned a motel in Pascagoula, Mississippi, which had deteriorated significantly and was being used improperly, attracting vagrants and drug users. The city council ordered the demolition of the motel after a hearing, citing it as a menace to public health and safety. Lee did not attend the hearing, but her son did. The city council decided the motel was beyond repair and ordered its demolition.Lee appealed the city council's decision to the Jackson County Circuit Court, arguing that the city failed to provide substantial evidence and did not comply with statutory notice provisions. The Circuit Court affirmed the city's decision. Lee then appealed to the Court of Appeals, which found that the city’s notice was insufficient and reversed and remanded the case for further determination.The Supreme Court of Mississippi reviewed the case on certiorari. The court found that the appeal was moot because the motel had already been demolished by a new owner, as admitted by Lee in her appellate filings. Additionally, Lee lacked standing to pursue the appeal because she had transferred the property to her son on the day of the city council meeting and no longer had any interest in it. Consequently, the Supreme Court of Mississippi vacated the Court of Appeals' decision and dismissed Lee's appeal. View "Lee v. The City of Pascagoula, Mississippi" on Justia Law

In November 2019, Sarah and her two minor children lived with her boyfriend, William Jeffrey Knight. Suspecting infidelity, Sarah searched Knight's phone and discovered a pornographic video of her twelve-year-old daughter, Jane. Sarah took the phone to the Petal Police Department, where officers viewed the video and conducted further investigation. Knight was indicted on two counts of child exploitation and one count of touching a child for lustful purposes.The Forrest County Circuit Court held a jury trial, where Knight was found guilty on all counts. He was sentenced to ninety-five years in prison and required to register as a sex offender. Knight filed motions to suppress evidence obtained from his phone, arguing that the search violated his Fourth Amendment rights. The motions were denied, and Knight appealed the decision.The Supreme Court of Mississippi reviewed the case. Knight raised several issues on appeal, including the legality of the warrantless search of his phone, prosecutorial misconduct, the validity of the search warrants, the presentation of false testimony, the proportionality of his sentence, and claims of ineffective assistance of counsel. The court found that the private search doctrine applied to the warrantless search of Knight's phone, as the police did not exceed the scope of Sarah's initial search. The court also determined that the prosecutor's conduct during cross-examination did not amount to misconduct and that the search warrants, despite clerical errors, were valid. The court found no evidence that the State knowingly presented false testimony and ruled that Knight's sentence was within statutory limits.The Supreme Court of Mississippi affirmed Knight's convictions and sentences, finding no cumulative error that would warrant reversal. View "Knight v. State" on Justia Law

In October 2020, Terrance Watts was indicted for the first-degree murder of his half-brother, Yancy Williams, by a grand jury in Hinds County, Mississippi. The incident occurred at a Marathon gas station where Williams was shot in the head by Watts. Surveillance footage and witness testimonies indicated that Williams was intoxicated and aggressive, leading to a physical altercation with Watts. Watts later turned himself in and admitted to the shooting, claiming he panicked.The Hinds County Circuit Court tried Watts in July 2023, where he was convicted of first-degree murder and sentenced to life imprisonment. Watts filed a post-trial motion for a judgment notwithstanding the verdict or a new trial, which was denied by the trial judge. Watts then appealed, raising three issues: the sufficiency of the evidence, the propriety of jury instruction S-4 on deliberate design killing, and the propriety of jury instruction S-2 regarding malice aforethought inferred from the use of a deadly weapon.The Supreme Court of Mississippi reviewed the case and found no error. The court held that the evidence was sufficient to support the conviction, as a rational juror could find each element of first-degree murder beyond a reasonable doubt. The court also found that jury instruction S-4 was proper and did not prejudice Watts, as it accurately stated the law. Additionally, the court held that jury instruction S-2 did not improperly comment on the weight of the evidence, as it was consistent with established legal principles. Consequently, the Supreme Court of Mississippi affirmed the conviction and sentence. View "Watts v. State of Mississippi" on Justia Law

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