Justia Mississippi Supreme Court Opinion Summaries

There was no abuse of the trial court’s discretion in denying a mistrial, no was there an abuse of discretion in handling the discovery of a prosecution’s expert’s testimony. A grand jury indicted Jesse Mouton on four counts of sexually assaulting N.B. Counts one and two charged Mouton with sexual battery. Counts three and four charged him with touching a child for lustful purposes. In this case, an expert witness testified that injuries to a child were consistent with sexual abuse. Her reports, photographs of the injured body area, and expert opinion were previously disclosed to the defense. Yet, at trial, the defense took issue with the expert’s testimony about the relevance of the shape of some of the injuries. After assessing the defendant’s request to exclude the expert’s testimony, the trial judge denied it. Though the court found no discovery violation, the judge recessed trial for the day so defense counsel could further interview the expert, and restricted the expert’s testimony to external injuries but allowed the expert to give an opinion that the child’s injuries resulted from sexual assault. The defendant appealed the outcome, arguing that the trial court’s actions in handling the expert’s testimony and report denied him a fair trial. Finding no reversible error in the trial court record, the Mississippi Supreme Court affirmed defendant’s convictions. View "Mouton v. Mississippi" on Justia Law

After review of the facts of this case, the Mississippi Supreme Court concluded that Dillon Williams waived his right to sentencing by jury when he pled guilty to burglary and aggravated assault. For those crimes, a circuit court sentenced him to twenty years for the assault, and twenty-five years for the burglary. The trial court added a twenty-year enhancement to the assault charge because Williams’ victim was an elderly woman. The Supreme Court affirmed the judgment of the trial court that denied Williams’s request for post-conviction relief, and affirmed the judgment of the Court of Appeals that affirmed the trial court. View "Williams v. Mississippi" on Justia Law

A jury found Alvin Brown guilty of manslaughter and four counts of aggravated assault. The circuit court sentenced Brown to twenty years in the custody of the Mississippi Department of Corrections for manslaughter and ten years for each aggravated assault conviction, with the aggravated assault sentences to run concurrently with each other and consecutively to the manslaughter sentence. Brown appealed and the Court of Appeal reversed and remanded for a new trial as to only the aggravated assault convictions due to a variance between the indictment and the jury instructions. Finding no merit as to Brown's appeal of the self-defense instruction, the appellate court affirmed. Because the Court of Appeals’ affirmed the trial court’s decision to give the State’s imperfect self-defense instruction, which conflicted with controlling caselaw affirming the refusal of imperfect self-defense instructions when requested by defendants, the Supreme Court also reversed Brown’s manslaughter conviction. View "Brown v. Mississippi" on Justia Law

The Mississippi Supreme Court concluded that the trial court record in this case supported a criminal-contempt finding beyond a reasonable doubt. Christopher Scott Routh was found in direct criminal contempt after he disrespected the court -specifically by standing up to dispute a judge’s bond ruling after the bond hearing had been concluded and despite being directed by the judge to sit down and make any further argument by written motion. View "Routh v. Mississippi" on Justia Law

The Mississippi Department of Corrections (MDOC) appealed the Chancery Court’s order granting the Roderick & Solange MacArthur Justice Center’s (Justice Center’s) complaint for declaratory judgment, deeming MDOC in violation of the Mississippi Public Records Act (MPRA) and requiring MDOC to produce records sought by the Justice Center. In November 2014, the Justice Center made a request under the MPRA for records pertaining to MDOC’s process and protocol for lethal injections, as well as MDOC’s acquisition of chemicals it intended or considered for use in lethal-injection executions. MDOC responded to the Justice Center’s 2014 request, furnishing documents, some of which were redacted. The Supreme Court concluded it would have been “ludicrous for this Court to blindly follow” the Mississippi Public Records Act of 1983 (MPRA) as it existed in 2014 when the documents at issue were requested, and “act as though we did not know the law, as adopted by the Legislature in 2016 and readopted in 2017.” The Supreme Court concluded it had to apply the Public Records Act to the this case “as though it has always read as it reads today,” vacated the trial court’s judgment, and rendered a decision in favor of the Mississippi Department of Corrections (MDOC). View "Mississippi Dept.of Corrections v. Roderick & Solange MacArthur Justice Center" on Justia Law

Janice Wilcher appealed her conviction for retaliation against a public servant for making a false representation of rape against Deputy Michael Townsend of the Scott County Sheriff’s Department. Wilcher claimed Section 97-9-127 was unconstitutionally vague. Wilcher further claimed the State failed to prove that Deputy Townsend suffered any actual harm, as alleged in the indictment. Finding no merit in either issue, the Mississippi Supreme Court affirmed. View "Wilcher v. Mississippi" on Justia Law

Tameshia Shelton was convicted by jury of the murder of Daniel Young. After the trial, Shelton filed a motion for judgment notwithstanding the verdict or in the alternative for a new trial. The trial court denied the motion. Shelton appealed, raising three issues: (1) challenging the sufficiency of the evidence; (2) alleging the verdict was against the weight of the evidence; and (3) alleging the trial court erred by denying her requested two-theory jury instruction. Finding no error, the Supreme Court affirmed her conviction. View "Shelton v. Mississippi" on Justia Law

Pro se appellant David Jackson appealed the Circuit Court’s denial of his Motion for Transcripts and Records. The Court of Appeals dismissed Jackson’s appeal for lack of jurisdiction. On certiorari review, the Supreme Court found the Court of Appeals correctly recognized the issue was lack of subject matter jurisdiction, but it was the trial court that lacked jurisdiction, not the appellate court. So the Supreme Court modified the Court of Appeals’ disposition and affirmed. View "Jackson v. Mississippi" on Justia Law

Eugene Martin was convicted of shooting into a dwelling and sentenced as a habitual offender under Section 99-19-81. He claimed one of his two prior qualifying felony convictions resulted in a sentence of less than one year. Section 99-19-81 authorizes the State to seek increased punishment for those charged with a felony offense after having twice been convicted of prior felonies. But for this statutory enhancement to apply, the State must prove each of the defendant’s prior felony convictions resulted in a sentence of one or more years in a state or federal prison. If the State sought enhanced sentencing, and the requirements were met, Section 99-19-81 mandated the court sentence the defendant to the maximum term of imprisonment for the subject offense - in this case ten years. Martin argued he was wrongfully subjected to the sentencing enhancement. After review, the Supreme Court agreed, affirmed Martin’s conviction for shooting into a dwelling, but reversed and remanded for resentencing. View "Martin v. Mississippi" on Justia Law

Hinds County Assistant Public Defender attorney Greg Spore appealed the order finding him in direct criminal contempt by Judge Jeff Weill Sr. of the Hinds County Circuit Court for displaying willful, contemptuous behavior that interfered with the orderly administration of justice. Spore represented Jeremy Cowards in an adjudication hearing, following the violation of his probation. Cowards had been indicted for house burglary and was ordered to Regimented Inmate Discipline (RID). After the pronouncement of guilt, Judge Weill asked whether the defense had any argument for the court to consider for sentencing. "Simply trying to make [his] record" on behalf of Cowards, Spore kept talking despite the trial court's admonition to stop. Finding that the record supported the trial court’s order beyond a reasonable doubt, the Supreme Court affirmed. View "Spore v. Mississippi" on Justia Law