Justia Mississippi Supreme Court Opinion Summaries

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In this case, the Supreme Court of Mississippi affirmed the conviction and sentence of Timothy Marbley for aggravated domestic violence. The case originated from an incident in April 2020, where officers responded to a disturbance at an apartment complex. They found Sherita Lynch, Marbley's girlfriend, with injuries and a trail of blood leading from the apartment. Marbley was not present at the scene. Lynch and Marbley both testified at the trial, providing different accounts of the incident.The court noted that Marbley's counsel had filed a brief asserting that there were no arguable issues for review and complied with the procedures set out in Lindsey v. State when an attorney believes there are no appealable issues. Despite being given an opportunity, Marbley did not file a pro se brief. After reviewing the entire record, the court concurred with Marbley's counsel and found no issues that warranted appellate review.Consequently, the court affirmed Marbley's conviction for aggravated domestic violence and his sentence of ten years, five of which were suspended with nonreporting, supervised probation. View "Marbley v. State of Mississippi" on Justia Law

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The case before the Supreme Court of Mississippi involves an appeal by Joe Exson, who was convicted of burglary of a dwelling, grand larceny, and first-degree arson. Exson was identified in a video committing these crimes, wearing a distinctive hoodie that was later found in his possession. He stole numerous items from the property and set it on fire, causing it to burn down entirely. The primary issue in Exson's appeal was the valuation of the stolen items, which was used to determine the charge of grand larceny. The property owner estimated the value of the stolen goods to be over $1,000, which is the minimum threshold for grand larceny under Mississippi law.Exson argued that the state failed to provide sufficient evidence of the fair market value of the stolen property and that the jury was improperly instructed on the value element of the larceny statute. However, the court noted that Exson failed to raise these arguments during his trial and thus, they were procedurally barred. Besides, the court found no merit in Exson's arguments as he was clearly seen committing the crime in the video. Moreover, reversing his larceny sentence would not substantially change his overall sentence since his arson sentence was longer and was to run concurrently.The court also examined the jury instructions and found that they tracked the language of the grand larceny statute correctly, even though they did not further define the element of value. Since Exson did not object to the instructions or request a definitional instruction during his trial, the court found no reversible error. Therefore, the Supreme Court of Mississippi affirmed Exson's convictions. View "Exson v. State of Mississippi" on Justia Law

Posted in: Criminal Law
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The Supreme Court of Mississippi reviewed a case where a city was sued for negligence due to its failure to disclose a juror's potential conflict of interest during a trial. The City of Picayune had originally sued Landry Lewis Germany Architects, alleging defects in an addition to the Picayune City Hall. A juror, Lorenzo Breland, was the son of a Picayune city councilman. The City's representative informed the City's counsel of this relationship, but took no further action. At the end of the trial, the court was informed of this relationship, leading to the dismissal of Breland and a mistrial. Landry Lewis then counter-sued the City for negligence due to its failure to disclose this familial relationship.The trial court found in favor of Landry Lewis, awarding them $210,000 in damages. However, on appeal, the Supreme Court of Mississippi reversed this decision. The court held that the City of Picayune did not owe a duty of care in tort to Landry Lewis that was breached by its failure to inform the trial court of the potential juror's familial relationship. The court reasoned that trials and voir dire are adversarial processes, and that it is incumbent upon both sides to perform their due diligence in identifying potential conflicts of interest. The court further noted that there were other mechanisms, such as sanctions or bar complaints, to address any perceived misconduct. Therefore, the award of damages for negligence was reversed and rendered. View "City of Picayune v. Landry Lewis Germany Architects, P.A." on Justia Law

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In this case conducted by the Supreme Court of Mississippi, the defendant, Keith Montrago Jackson, was charged and convicted of sexual battery and sentenced to life imprisonment. The case stemmed from an incident involving Jackson and his girlfriend's twelve-year-old daughter, Anna. Jackson and Anna went to a store late at night, and upon their return, Jackson sexually assaulted Anna in his truck. Anna reported the incident to her school, and law enforcement was contacted.At trial, Anna testified about the incident and identified Jackson as the perpetrator. Forensic evidence, including sperm cells found in Anna that matched Jackson's DNA, was presented. Jackson testified in his own defense, denying the allegations. However, he was convicted and sentenced to life imprisonment.Jackson appealed the conviction, but his appellate counsel found no arguable issues for appellate review. The Court, having independently reviewed the record, also found no arguable issues. The Supreme Court of Mississippi affirmed the trial court's judgment. View "Keith Montrago Jackson a/k/a Keith Jackson v. State of Mississippi" on Justia Law

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In this case, the Supreme Court of Mississippi reviewed the convictions and death sentences of Willie Cory Godbolt, who was found guilty of several counts of murder, kidnapping, attempted murder, and armed robbery. The Court addressed numerous issues raised by Godbolt, including whether the trial court erred by denying his motions to sever the charges, transfer the trial venue, limit voir dire, suppress certain evidence, and exclude victim impact testimony. Godbolt also claimed that his counsel provided ineffective assistance and that his death sentences were unconstitutional.The Court rejected all of Godbolt's claims, finding no error in the trial court's decisions or in the handling of his case. It affirmed Godbolt's convictions and sentences, holding among other things that the evidence supported the jury's findings of guilt and the imposition of the death penalty, the trial court properly admitted certain evidence, and Godbolt's counsel did not provide ineffective assistance. The Court also found that Godbolt's death sentences did not violate the constitution. View "Godbolt v. State of Mississippi" on Justia Law

Posted in: Criminal Law
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The Supreme Court of Mississippi has once again ruled on the case of Robert Stratton, who has been fighting for the possession of his 1949 International KB 3/4-ton truck. In 2006, Stratton left his truck at a repair shop. In 2009, Jerry McKey, who had bought the shop, refused to return the truck unless Stratton paid storage fees. This led to a series of legal battles, with Stratton ultimately being awarded possession of the truck and $1350 in damages, and McKey being denied his claim for storage fees.In 2021, Stratton discovered his truck, which he had believed to be destroyed, restored and in Brookhaven, Mississippi. He filed a motion to vacate the previous court decisions, arguing that the truck's existence invalidated the previous rulings. However, the Supreme Court of Mississippi disagreed. It affirmed the trial court's denial of Stratton's motion to vacate, stating that Stratton is entitled to immediate possession of the truck and $1350 in damages, and he owes McKey no storage fees.The court found no grounds for Stratton's claims of fraud or new evidence, and it emphasized the importance of finality in court judgments. It also noted that the trial court had considered the potential of a double award to Stratton, but chose not to alter its judgment because Stratton's initial complaint had requested damages on multiple claims. The court concluded that the decision to deny Stratton's motion to vacate was within the trial court's discretion and should remain undisturbed. View "Stratton v. McKey" on Justia Law

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The case involves the Mississippi Division of Medicaid and the Women’s Pavilion of South Mississippi, PLLC. Women's Pavilion, a physician-owned OBGYN clinic, challenged Mississippi Division of Medicaid's calculation of the "encounter rate," a set amount of money per visit by a Medicaid patient. Medicaid set the clinic’s encounter rate at $157.94, which was partially based on the compensation of the five physician owners of the clinic.Women’s Pavilion appealed this decision and requested an administrative hearing. The hearing officer evaluated whether Medicaid’s initial decision was supported by substantial evidence, affirming the reimbursement rate. However, Women’s Pavilion appealed again, arguing that the hearing officer applied the wrong standard of review.The Hinds County Chancery Court agreed with Women’s Pavilion, holding that the hearing officer should have made his own findings of fact and determinations of the issues presented, rather than merely evaluating whether Medicaid’s initial decision was supported by substantial evidence. The court vacated Medicaid’s final decision and remanded the matter back to Medicaid.The Mississippi Division of Medicaid appealed to the Supreme Court of Mississippi. The Supreme Court affirmed the decision of the Hinds County Chancery Court, stating that the hearing officer had erred by applying the standard of review for courts reviewing a final administrative decision, rather than following Medicaid’s own administrative rules governing provider appeals. The case was remanded back to Medicaid for further proceedings under the proper standard of review. View "Mississippi Division of Medicaid v. Women's Pavilion of South Mississippi, PLLC" on Justia Law

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In this case, the Supreme Court of Mississippi affirmed the trial court's dismissal of a case brought by John E. Federinko against Forrest County and its coroner, Butch Benedict, Jr. Federinko, the father of Alison Dawkins, disagreed with the findings of the county's investigation into his daughter's death by suicide. He argued that the county had a ministerial duty to perform an autopsy and to obtain postmortem blood and vitreous fluids, which they had failed to do. His subsequent private autopsy suggested that his daughter's death may have been a homicide.The court, however, ruled that Forrest County had no duty to perform an autopsy and did not breach any duty to obtain or attempt to obtain postmortem blood and fluids. They found that even if Federinko's suspicions were correct and his daughter's death was not a suicide, that would not change the county's obligations. The court concluded that Federinko failed to allege a tortious act, rendering the issue of discretionary-function immunity moot. Therefore, the trial court's denial of Federinko's motion for partial summary judgment, as well as its grant of Forrest County's motion for summary judgment and subsequent dismissal of the case, were affirmed. View "Federinko v. Forrest County, Mississippi" on Justia Law

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The Supreme Court of Mississippi affirmed the trial court's decision to reform an irrevocable trust to reflect the original intent of the settlor. The settlor, Elton G. Beebe Sr., created a trust in 1992 with the aim of providing lifetime benefits to 16 named individuals. However, he claimed that a scrivener’s error in the trust document led to a misunderstanding about the distribution of the trust's assets upon the death of the last named beneficiary. The trust document stated that the assets would be distributed to the descendants of all 16 beneficiaries, but Beebe claimed that his intention was for the assets to be distributed to his own lineal descendants.The trial court found that the settlor provided clear and convincing evidence of his original intent and the mistake in the trust document. It reformed the termination provision of the trust to reflect the settlor's intent. The decision was appealed by several parties who were not in agreement with the reformation.The Supreme Court upheld the trial court's decision, finding that there was sufficient evidence to prove that the termination provision in the trust was a mistake of expression that did not reflect Beebe's intent at the time the trust was created. The court did not find any abuse of discretion in the trial court's finding. View "In the Matter of the Elton G. Beebe, Sr. Irrevocable Family Mortgage Trust v. Family Management, Inc." on Justia Law

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The case at hand involves an appeal from Lady B. Garth against the Monroe County Circuit Court's dismissal of her appeal of a criminal misdemeanor conviction. The Supreme Court of Mississippi was tasked with determining whether the lower court erred in this dismissal.The pivotal issue revolved around the procedural aspects of perfecting an appeal from a justice court to a circuit court. According to Mississippi law, this requires a simultaneous filing of a written notice of appeal, a cost bond, and an appearance bond within 30 days of judgment. In this case, Garth failed to comply with these requirements. While she faxed a written notice of appeal on the 30th day following the original judgment, the cost bond and appearance bond were not submitted until six days later.The court concluded that Mississippi law does not permit the filing of the required bonds past the 30-day appeal time, and as such, the Monroe County Circuit Court committed no error in dismissing Garth's appeal. Therefore, the Supreme Court of Mississippi affirmed the lower court's decision.It should be noted that while Garth raised additional issues concerning the merits of the underlying justice-court judgment and alleged ineffective assistance of counsel, these were deemed outside the scope of the present appeal or more appropriately raised in post-conviction-relief petitions, and were thus not considered by the court in this decision. View "Garth v. State of Mississippi" on Justia Law

Posted in: Criminal Law