Justia Mississippi Supreme Court Opinion Summaries

The Mississippi Baptist Foundation and various heirs of the decedent’s wife both claimed ownership over certain mineral interests devised in the decedent’s will at the time of the decedent’s death in 1969. The will left most of the estate, including the mineral interests, to the Mississippi Baptist Foundation as trustee, with income from the trust going to the decedent’s wife for life, then to his sister for life, and then to benefit the Mississippi Baptist Foundation’s foreign missions. In 1969, Mississippi had mortmain laws (repealed in 1992 and 1993), the relevant portion of which provided that after ten years in the possession of certain proscribed institutions, including religious institutions, real property reverted to the decedent’s heirs if the institution failed to sell the property within that ten-year time period. The Mississippi Baptist Foundation and the heirs disagreed as to when the ten-year period began in this case, and, if it applied, whether the mortmain laws were unconstitutional. The trial court found that the mortmain laws were triggered on the date of the decedent’s death in 1969 and that the mortmain laws were constitutional. Because the Mississippi Baptist Foundation had a possessory interest in the mineral interests in 1969, and because it failed to timely assert any claims regarding the property after it gained possession in 1969, the Mississippi Supreme Court affirmed the trial court. View "Mississippi Baptist Foundation v. Fitch, et al." on Justia Law

This case concerned the removal of two commissioners of the Canton Municipal Utilities Commission (CMU Commission) by the City of Canton Board of Aldermen (the Board). The Mayor of Canton vetoed a resolution of the Board issuing notice and an opportunity to be heard to the commissioners. The Board claimed to override the veto by a vote of two-thirds of the majority of members, although in actuality it failed for lack of the requisite majority. It then proceeded with a hearing and ultimately removed the commissioners from their appointed positions. The decision of the Board was appealed. The circuit court reversed the decision to remove the commissioners, finding that the Board failed to override the Mayor’s veto and that the actions taken to remove the commissioners following the failure to override the veto were void as a matter of law. The Board appealed to the Mississippi Supreme Court, claiming the commissioners’ notice of appeal contained fatal jurisdictional errors, notice and an opportunity to be heard were not required for the removal to be effective and the Board properly overrode the Mayor’s veto. After a careful review of the law, the Supreme Court affirmed the circuit court's judgment. View "City of Canton Board of Aldermen v. Slaughter, et al." on Justia Law

Lorenzo Manuel was convicted by jury of second-degree murder and aggravated assault. At sentencing, the trial judge found that Manuel was a habitual offender and sentenced him to forty years for second-degree murder and twenty years for aggravated assault. The judge ordered that these sentences were to run consecutively and without reduction, suspension, or possibility of parole. Manuel appealed, and the Mississippi Court of Appeal affirmed the trial court's judgment. The Mississippi Supreme Court granted Manuel’s petition for writ of certiorari to review the trial judge’s imposition of a habitual offender sentence. The Supreme Court found that the trial judge lacked sufficient evidence to sentence Manuel as a habitual offender. Additionally, the Court found that the Court of Appeals erred when it allowed the State to supplement the record with copies of the indictments for Manuel’s prior offenses. Therefore, the Court vacated Manuel’s habitual offender sentence and remanedd the case to the trial court to resentence Manuel as a nonhabitual offender. View "Manuel v. Mississippi" on Justia Law

Alberto Garcia confessed to raping and murdering five-year-old JT. He pled guilty to capital murder and waived jury sentencing. After a hearing, the trial judge sentenced Garcia to death. He appealed his sentence, and the Mississippi Supreme Court affirmed. He sought post-conviction relief from his sentence or leave to proceed in the trial court for further post-conviction proceedings. In his motion, Garcia argues his trial counsel provided constitutionally ineffective assistance. While he asserted his attorneys were deficient for three reasons, his primary claim was that counsel failed to pursue and present at the sentencing hearing evidence of fetal alcohol syndrome disorder (FASD) as a mitigating factor. After review, the Supreme Court found Garcia failed to present a substantial showing that his trial attorneys were deficient in investigating potential FASD, let alone that any prejudice resulted. "[T]here is no reasonable probability that FASD evidence would have caused the sentencing judge to find that the mitigators outweighed the aggravators, which included the heinous nature of Garcia’s crime." The Court likewise found Garcia failed to show deficiency and resulting prejudice on his other two ineffective-assistance-of-counsel claims. Therefore, his motion was denied. View "Garcia v. Mississippi" on Justia Law

Marlon Howell was indicted by grand jury for the sale of a controlled substance in 1998. The indictment charged Howell with one count of the sale of 6.8 grams of marijuana, a Schedule 1 controlled substance. At the time of Howell’s charging, Mississippi Code Section 41-29-139(b)(3) (Rev. 1993) provided for a penalty of three years’ imprisonment and/or a fine up to $3,000 for the sale of one ounce or less of marijuana. In 1999, the State and Howell agreed to reduce Howell’s felony charge from the sale of a controlled substance to possession of a controlled substance. The parties presented an agreed order reducing Howell’s felony charge to possession. On the same day, Howell pled guilty to the reduced felony charge of possession of a controlled substance. Howell was thereafter sentenced to three years in custody of the Mississippi Department of Corrections with one year of house arrest and the remaining two years of post-release supervision in addition to $200 in restitution. In 2016, Howell moved to vacate the sentence for felony possession, arguing the sentence he received was illegal. The trial court treated Howell’s motion as a post-conviction relief petition and found that Howell lacked standing under Mississippi’s post-conviction relief statutes because Howell had already completed his sentence for drug possession. Howell then appealed. The Mississippi Supreme Court reversed and remanded, finding that “[o]n the narrow question presented, interpreting Mississippi Code Section 99-39-5(1), we hold that Howell has standing.” On remand, the trial court found that Howell’s post-conviction relief petition was time-barred. The court also found that the original sentence was not illegal and that Howell had benefitted from a more lenient sentence for the crime with which he was originally charged. Howell appealed the trial court’s denial of his motion for post-conviction relief. Finding no reversible error in the trial court's judgment, the Supreme Court affirmed. View "Howell v. Mississippi" on Justia Law

Handy Willis, Jr. appealed his conviction of first degree murder under Mississippi Code Section 97-3-19(1)(a) (Rev. 2020). Willis was found guilty of shooting and killing his former girlfriend, Tamaneka Alexander for which he was sentenced to imprisonment for life without the possibility of parole. He argued "[t]he trial court erred in three critical ways that deprived [him] of a fair trial:" (1) by violating his constitutional right to confront Police Captain Pete Williams, the lead investigator assigned to his case, about the officer’s prior inconsistent statement; and (2) the trial court erroneously denied his self-defense jury instruction. He also asserted the evidence was insufficient to support his conviction. The Mississippi Supreme Court concluded Willis’s right to cross examine fully and confront Captain Williams was violated. "Willis should have been allowed to confront Captain Williams with the recording of his prior inconsistent statement." Although the Court found there was a violation of the Confrontation Clause, the Court also found this was harmless error. The record did not support the giving of a self-defense jury instruction. Giving the prosecution the benefit of all reasonable inferences, the Supreme Court concluded the evidence supported Willis’s conviction for first degree murder. Accordingly, the judgment was affirmed. View "Willis v. Mississippi" on Justia Law

Joseph Bland was convicted by jury of first-degree murder after he shot and killed his girlfriend, Olletta Jones. Bland appealed, claiming the trial court erred by excluding Bland’s testimony regarding his post-traumatic stress disorder (PTSD), thereby depriving him of the right to assert his defense. Finding no error in the trial court’s decision, the Mississippi Supreme Court affirmed Bland’s conviction. View "Bland v. Mississippi" on Justia Law

Robert Fisher appealed his convictions for several drug possession and trafficking charges, and his sentence as a habitual offender. Fisher argued his right to testify was violated, that officers unlawfully searched a storage unit he was leasing, and that the trial judge sentenced him as a habitual offender without sufficient evidence. Finding no reversible error in the circuit court's judgment, the Mississippi Supreme Court affirmed. View "Fisher v. Mississippi" on Justia Law

A probation officer improperly induced L.J. Green III to give a statement that led to the discovery of the linchpin evidence used against Green at his robbery trial. While the trial judge suppressed Green’s statement, the judge still admitted evidence that Green possessed the victim’s car keys—evidence that was wholly derived from Green’s excluded statement. This evidence was admitted over Green’s objection. The jury convicted Green. On appeal, both Green and the State agreed the trial judge wrongly admitted the tainted evidence. Though the State claimed the error was harmless, this evidence strongly contributed to Green’s guilty verdicts. So the Mississippi Supreme Court concluded the evidence's admission was not harmless error. Green’s conviction and sentence were reversed and the matter remanded for a new trial. View "Green v. Mississippi" on Justia Law

Ladarrius Garrett was convicted by jury of the burglary of a hotel room. He claimed his conviction was not supported by sufficient evidence and that the jury’s guilty verdict was contrary to the overwhelming weight of the evidence. Finding no merit to either claim, the Mississippi Supreme Court affirmed Garrett’s burglary conviction. View "Garrett v. Mississippi" on Justia Law