Justia Mississippi Supreme Court Opinion Summaries

On July 14, 2023, an individual left his car, a 2003 red Ford Mustang, in a restaurant parking lot in Hattiesburg, Mississippi, with the keys inside. When he returned in the early hours of the next day, the car was missing. The theft was reported to the police, and the car’s information was entered into the National Crime Information Center. Later that same day, police in Starkville responded to a call at another restaurant and found Isaac Merrimon sitting in the missing vehicle next to a small fire. Merrimon claimed he had purchased the car for eight dollars and produced a handwritten note as supposed proof, but the owner testified he had not sold or given permission for the use of the car and did not know Merrimon.The Circuit Court of Oktibbeha County tried Merrimon for receiving stolen property. At trial, both the car’s owner and a police officer testified to the vehicle’s value, using Kelley Blue Book estimates to establish it was worth at least $1,600. The jury found Merrimon guilty, and he was sentenced as a habitual offender to five years without parole. Post-trial motions for a new trial or judgment notwithstanding the verdict were denied, and Merrimon appealed, arguing errors in the jury instructions, insufficiency of the evidence, and that the verdict was against the weight of the evidence.The Supreme Court of Mississippi reviewed the case. It held that, when considered as a whole, the jury instructions accurately conveyed the law, including the requirement of proving both possession and guilty knowledge. The Court also found sufficient evidence supported the conviction and that the verdict was not against the overwhelming weight of the evidence. Accordingly, the Supreme Court affirmed the conviction and sentence. View "Merriman v. State of Mississippi" on Justia Law

A teenage girl shot and killed her mother and wounded her stepfather after her mother confronted her about drug use at home. Shortly before the incident, she was undergoing psychiatric treatment for depression and anxiety, and her medication regimen had recently changed. After the shootings, she attempted to conceal evidence, contacted friends, and made statements indicating awareness of her actions. Physical and forensic evidence, including gunshot residue and video footage, linked her to the crimes.The Rankin County Circuit Court indicted her for first degree murder, attempted murder, and tampering with physical evidence. At trial, she raised the insanity defense, presenting expert testimony that she was experiencing severe mental illness and did not comprehend the wrongfulness of her acts. The State countered with expert testimony suggesting she understood her actions. The jury rejected the insanity defense, found her guilty on all counts, and sentenced her to life imprisonment for murder and attempted murder, and ten years for tampering, with the sentences to run concurrently. The trial judge denied her post-trial motions.The Supreme Court of Mississippi reviewed the case and considered multiple alleged errors, including issues with continuances, mental health evaluations, evidentiary rulings, jury instructions, sentencing procedures, and prosecutorial comments. The Court held that none of the alleged errors warranted reversal, emphasizing that the sentencing instructions, while not ideal, did not result in an illegal sentence. Importantly, it clarified that under the applicable statute, “life imprisonment” for the juvenile defendant does not mean life without parole for first degree murder or attempted murder. The Court concluded that the trial proceedings and sentences complied with both statutory and constitutional requirements and affirmed the convictions and sentences. View "Gregg v. State of Mississippi" on Justia Law

During a large public event in Yazoo County, Mississippi, an altercation developed between Johnny Lee House Jr. and Christopher Turnage. After a verbal exchange, House walked away but was followed by Turnage. House then turned, drew a gun from his backpack, and fired a single shot at Turnage in a crowd of approximately two hundred people. This initial gunshot was followed by multiple others from bystanders, resulting in the death of Turnage and serious injury to Amanda Gatlin, who was struck in the head. Nearly one hundred shell casings were found at the scene.A jury in the Yazoo County Circuit Court convicted House of manslaughter for Turnage’s death and aggravated assault for Gatlin’s injury. The trial court sentenced House to twenty years for manslaughter and twenty years for aggravated assault, with ten years suspended. During trial, the court limited the testimony of a defense witness regarding another shooter because the defense had failed to supplement discovery with this information, as required by procedural rules. The court also gave a jury instruction on aiding and abetting, which the defense challenged.On appeal, the Supreme Court of Mississippi reviewed whether sufficient evidence supported the aggravated assault conviction, whether the limitation on the defense witness’s testimony was proper, and whether the aiding and abetting jury instruction was erroneous. The Court held that House’s act of firing into a crowd and initiating a shootout was the proximate cause of Gatlin’s injury, thus satisfying the statutory elements of aggravated assault even if House’s bullet did not strike her. The Court found no abuse of discretion in the exclusion of the defense witness’s additional testimony, and any error would have been harmless. The Court also concluded that the jury instruction on aiding and abetting, even if unnecessary, did not prejudice House. The Supreme Court of Mississippi affirmed House’s convictions. View "House v. State of Mississippi" on Justia Law

Three related business entities and an individual were audited by the Mississippi Department of Revenue (MDOR) for sales and income taxes covering various periods between 2019 and 2021. After a meeting to discuss the audit results, the taxpayers updated their mailing address with MDOR. MDOR subsequently determined that the entities and individual owed tax assessments and mailed these assessments to the updated address. The taxpayers later claimed they did not receive the assessments and missed the statutory deadline to appeal.The taxpayers attempted to appeal the assessments to the MDOR Board of Review, but their appeal was denied as untimely. They then appealed to the Board of Tax Appeals, which also affirmed the denial. The taxpayers next appealed to the Hinds County Chancery Court, arguing that MDOR had not sufficiently proven the assessments were actually mailed and that the statutory notice provisions violated due-process rights. Both parties moved for summary judgment. The chancery court granted summary judgment in favor of MDOR, finding the statutory notice provisions had previously been upheld as constitutional.The Supreme Court of Mississippi reviewed the case de novo, considering both the grant of summary judgment and the legal questions presented. The Court held that MDOR had provided sufficient evidence, through affidavits and mailing records, to establish that the assessments were mailed according to statutory requirements. The Court also held that the notice provisions in Mississippi Code Sections 27-65-37(2) and 27-77-5(1) are constitutional, as they are reasonably calculated to provide notice and an opportunity to contest the assessments, satisfying due-process requirements. The judgment of the Hinds County Chancery Court was affirmed. View "Carroll Brothers, LLC v. Graham" on Justia Law

A former county court judge in Leflore County, Mississippi, sought to run for county court judge in the general election scheduled for November 3, 2026. After filing his qualifying statement of intent, the current judge filed a petition with the Leflore County Election Commission, asserting that the former judge did not meet the residency requirements for candidacy because he had sold his Leflore County home and moved to Grenada County in 2023. The petition argued that the candidate had not resided in Leflore County for the required two years before the qualifying date or before the election date.The Leflore County Election Commission held a hearing, during which the candidate challenged the commission’s jurisdiction to decide candidate qualifications for county court judge. The commission consulted the secretary of state’s office, which indicated the commission had authority to review qualifications under relevant statutes. The commission then voted to disqualify the candidate, removing his name from the ballot. The candidate appealed to the Circuit Court of Leflore County. The circuit court ruled that the election commission did not have jurisdiction to determine the qualifications of a county court judge candidate and ordered the candidate’s name be placed back on the ballot. In the alternative, the circuit court found that the commission had applied the wrong residency standard.On appeal, the Supreme Court of Mississippi affirmed the circuit court’s judgment that the election commission lacked statutory authority to rule on the qualifications of candidates for county court judge, as the relevant statutes specifically excluded such offices from the commission’s jurisdiction. The court vacated as moot the remaining parts of the circuit court’s judgment, found the commission’s exclusion of the candidate improper, and directed that the candidate’s name be returned to the ballot. View "In Re: Petition to Disqualify Adams" on Justia Law

The case concerns a closely contested Democratic primary election for alderman of Ward 3 in Senatobia, Mississippi, in which Allen Tanksley defeated Michael Cathey by a single vote. Cathey alleged several irregularities in the handling of absentee ballots, including that some were improperly counted or excluded, that absentee ballots were not properly distinguished from regular ballots, that the ballot box was not properly secured, and that he was denied timely access to examine the ballot box and related materials.Following the election, the Tate County Democratic Executive Committee initially determined that irregularities warranted a new election, but the Chancery Court of Tate County set aside this determination and issued an injunction. Cathey then filed a formal election contest in the Circuit Court of Tate County, alleging procedural and substantive errors affecting the election’s outcome. After a hearing, the circuit court found that Cathey had not met his burden of proof on any claim. The court upheld the validity of a written agreement giving authority over the ballot box to the city clerk, found Cathey was not denied access to relevant materials, and concluded that there was no evidence of fraud or improper ballot tampering. The circuit court declared Tanksley the winner.Cathey appealed to the Supreme Court of Mississippi. The Supreme Court found that the city clerk’s breaking of the ballot box seal, in violation of Mississippi Code Section 23-15-911, constituted a “gross violation” of mandatory election law, creating a loss of confidence in the election’s integrity, especially given the unexplained counting of a contested absentee ballot. The Court held that, even absent proof of fraud, the breach of ballot box security warranted a special election. Accordingly, the Supreme Court of Mississippi reversed the circuit court’s judgment and ordered a new special election for the office. View "Cathey v. Tanksley" on Justia Law

A healthcare technology company formed in 2016 included the appellant as a founding member. The company’s operating agreement was modified several times, and in August 2020, the appellant assigned his membership interest to another member and a separate entity, ceasing to receive further distributions. Two years later, the appellant, through counsel, alleged that the assignment was executed under duress and fraud, and that there were improprieties with the amended operating agreements. In February 2024, the appellant, joined initially by another individual, filed suit against several members and the company, alleging negligent misrepresentation, securities violations, interference with contractual relations, conspiracy, conversion, and breach of fiduciary duty.The Harrison County Circuit Court, upon motion from the defendants, granted summary judgment, determining that all of the appellant’s claims were barred by Mississippi’s three-year statute of limitations. The court held that the appellant’s injury accrued at the time of the assignment in August 2020, and that the complaint filed in February 2024 was untimely. Arguments regarding forgery of an earlier operating agreement were found irrelevant to the assignment. Subsequent efforts by the appellant to supplement the appellate record with new evidence were denied after a limited remand from the Supreme Court of Mississippi.On appeal, the Supreme Court of Mississippi reviewed only the appellant’s arguments concerning the denial of record supplementation, as he failed to challenge the grant of summary judgment in his primary brief. The Court held that issues not raised in the appellant’s initial brief are waived, and the pro se status of the appellant did not excuse this failure. The Court also found no abuse of discretion in denying the request to supplement the record. Accordingly, the Supreme Court of Mississippi affirmed the trial court’s grant of summary judgment. View "Johnson v. Nichols" on Justia Law

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