Jabrien Williams was twenty-two years old when he convinced fourteen-year-old JR to unlock the window of an unoccupied bedroom of her family’s ground-floor apartment. Once inside, Williams had sex with the JR. Days later, Williams texted JR, attempting to have sex with her again. Soon after, JR’s stepfather discovered the messages on the family’s iPod. JR told her stepfather that Williams sent the messages to her. She then informed her mother she had sex with Williams in their apartment. Williams was indicted on one count of sexual battery. Before trial, Williams’s counsel disclosed that one of Williams’s defense theories would be that someone else—namely, Williams’s younger brother, who went to school with JR—sent the text messages from Williams’s phone. But at trial, Williams employed a different defense, steadfastly denying that the phone number used to send JR the messages was his. His younger brother also testified the number was not Williams’s. The State ran the phone number through the Madison County Detention Center logs. After the State rested, it learned this exact phone number was listed by Williams as his contact number when he received an ankle monitor for an unrelated crime. Realizing Williams had been wearing the GPS monitor during the relevant time frame, the State inquired further and learned GPS coordinates placed Williams at JR’s apartment the night she reported he had sex with her. Over Williams’s objection, the judge permitted the State to introduce this evidence during its rebuttal. On appeal of his conviction, Williams challenged several evidentiary rulings, significantly the admission of the State's rebuttal evidence. The Mississippi Supreme Court found no abuse of discretion in the trial court's ruling, and affirmed. View "Williams v. Mississippi" on Justia Law

While he was incarcerated, Lavar Williams’s jailers recorded numerous telephone conversations in which Williams appeared to be directing a drug trafficking ring. A search of Williams’s home revealed large amounts of marijuana and cocaine, as well as $93,259 in cash. Williams was subsequently charged and convicted of two counts of conspiracy and two counts of possession with intent to distribute. On appeal, Williams contended that he could not be in possession, constructive or otherwise, of drugs found in his home when he had been had been incarcerated for two months and others had access to the home. The Court of Appeals affirmed Williams’s conviction on a constructive possession theory. The Mississippi Supreme Court affirmed too, though the Court took this opportunity to clarify that Williams’s conviction should have been affirmed based on accomplice liability rather than constructive possession. View "Williams v. Mississippi" on Justia Law

The University of Mississippi Medical Center (UMMC) appealed a county court judgment granting Genevieve Jensen’s motion for extension of time to serve process on the attorney general and its decision denying UMMC’s motion for summary judgment based on a statute of limitations defense. Since Jensen failed to articulate good cause for an extension of time to serve process, the Mississippi Supreme Court determined the county court abused its discretion by granting her motion for extension, it reversed the county court’s decision and dismissed Jensen’s case with prejudice. View "University of Mississippi Medical Center v. Jensen" on Justia Law

The Mississippi Department of Employment Security (MDES) appeals from the circuit court’s order reversing the MDES Board of Review’s determination that Danny Leeton was an employee of Dover Trucking, LLC (Dover). Because the agency’s decision was supported by substantial evidence and was not arbitrary or capricious, the Mississippi Supreme Court concluded the circuit judge erred by reversing it. Accordingly, judgment was reversed and MDES' decision was reinstated. View "Mississippi Department of Employment Security v. Dover Trucking, LLC" on Justia Law

Kobe Augustine was convicted of second-degree murder for the killing of Nigel Poole. A divided Court of Appeals reversed and remanded Augustine’s conviction, opining that the circuit court erred by admitting hearsay testimony and that the error was not harmless. The Mississippi Supreme Court reversed, finding that consistent with Mississippi law, the circuit court did not err by allowing an officer to testify to the content of a witness’s prior statement for the purpose of impeachment. But even assuming that doing so was erroneous, the evidence against Augustine overwhelmingly supported his conviction. View "Augustine v. Mississippi" on Justia Law

The Mississippi Court of Appeals vacated Norris Alexander’s life-without-parole sentence as a habitual offender under Mississippi Code Section 99-19-81 (Rev. 2020). The Court of Appeals held that the Circuit Court erred by denying Alexander’s motions for funds to hire a mitigation investigator and an adolescent-development psychologist for his Miller v. Alabama hearing. The State petitioned the Mississippi Supreme Court for certiorari, which was granted. Finding that the trial court did not abuse its discretion by denying the motions for expert funding, the Supreme Court reversed the Court of Appeals’ decision, and reinstated and affirmed the trial court’s sentencing order. View "Alexander v. Mississippi" on Justia Law

A D’Iberville police officer arrested Damian Brown after spotting a firearm during a traffic stop. Brown appealed his resulting conviction for three counts of possession of a controlled substance and one count of unlawful possession of a firearm by a convicted felon. The trial court sentenced Brown to a total of twenty-four years to be served day for day without the benefit of early release or probation under Mississippi Code Section 99-19-81 (Rev. 2020), the habitual offender statute. Brown’s defense counsel filed a motion for JNOV or, alternatively, a new trial. The court denied the motions. To the Mississippi Supreme Court, Brown contended the trial court erred in denying his motions. The Supreme Court concluded the jury instructions given fairly and accurately announced the law of the case concerning constructive possession. The Supreme Court further found the trial court did not abuse its discretion by denying Brown’s proposed jury instruction D-11 as it had already been fairly covered elsewhere in the instructions by the State’s jury instruction S-5, a more complete and accurate statement of the law. Furthermore, the Court concluded Brown was not entitled to a circumstantial evidence jury instruction based on Nevels v. Mississippi. Therefore, the Supreme Court affirmed the trial court. View "Brown v. Mississippi" on Justia Law

Seth Copes was convicted on two counts of sexual battery of two minors. He was sentenced to twenty years on each count, to be served consecutively. Copes appealed, and the Court of Appeals affirmed his conviction and sentence. The Mississippi Supreme Court granted certiorari for the purpose of addressing Copes’s argument that he was denied his counsel of choice. Finding no reversible error, the Supreme Court affirmed Copes' convictions. View "Copes v. Mississippi" on Justia Law

The City of Gautier granted David Vindich a permit to build a 1,410 square foot garage/workshop on his .76 acre lot. When the building was almost completed, Vindich’s neighbor, Martin Wheelan, filed a lawsuit arguing the City’s decision was unlawful because Vindich actually sought a variance, which required a public hearing rather than a building permit. Thus, Wheelan said he was denied due process. Wheelan also claimed the City’s decision was arbitrary and capricious and that the workshop “completely overwhelm[ed]” the neighborhood and created a nuisance. After a trial, the chancellor dismissed Wheelan’s claims, finding that the City’s interpretation of the applicable ordinance was not manifestly unreasonable. The chancellor also found that the building was not a nuisance. Wheelan appealed, but the Court of Appeals affirmed. The Mississippi Supreme Court agreed with the appellate court's dissenting opinion, finding the City erred in its interpretation of the ordinance at issue here. The Court therefore reversed the Court of appeals and the chancery court, and remanded for further proceedings. View "Wheelan v. City of Gautier, et al." on Justia Law

Sedric Sutton sought compensation under Mississippi Code Sections 11-44-1 to -15 (Rev. 2019), Compensation to Victims of Wrongful Conviction and Imprisonment, after his conviction of possession of a controlled substance with intent to distribute was vacated by the Mississippi Supreme Court. He argued his conviction was reversed on grounds not inconsistent with innocence and that the crime he committed was not a felony. Because Sutton failed to demonstrate a genuine issue of material fact, the Mississippi Supreme Court affirmed the trial court's dismissal of his claims. View "Sutton v. Mississippi" on Justia Law