Justia Mississippi Supreme Court Opinion Summaries

Before his capital-murder trial, Laqunn Gary moved to suppress his confession, arguing he had not knowingly, intelligently, and voluntarily waived his Miranda rights. The trial court denied his motion without a hearing. The Supreme Court found that the trial court erred: because Gary had questioned the voluntariness of his confession, he had a due-process right to a suppression hearing. And the State had the burden to prove his confession was in fact voluntary. The Court therefore remanded this case to the trial court to conduct a hearing to determine the admissibility of Gary’s confession. View "Gary v. Mississippi" on Justia Law

In 1992, Arvin Rochell was indicted for two counts of capital murder for killing Hazel and Nell McMahan, and for one count of arson. Arvin Rochell, acting pro se, appealed the Circuit Court’s denial of his petition for post-conviction relief. Rochell styled his petition as a “Motion to Clarify Parole Eligibility” and argued that he was “being unlawfully held in custody due to [the] Mississippi Department of [Corrections’] holding that he is ineligible for parole under [Mississippi Code Section] 47-7-18(1)[.]” Rochell cited the first part of Section 47-7-18(1), which stated that “Each inmate eligible for parole pursuant to Section 47-7-3, shall be released from incarceration to parole supervision on the inmate’s parole eligibility date, without a hearing before the board, if . . .” Relying on this language, Rochell argued that all parole-eligible inmates like himself “are now subject to the new parole release procedures in 47-7-18.” He further argued that the Mississippi Department of Corrections (MDOC) was incorrect when it determined that Section 47-7-18 applied only to inmates sentenced after July 1, 2014, the date that Section 47-7-18 took effect. Rochell argued Section 47-7-18 applied retroactively to all parole-eligible offenders. The Supreme Court concluded that 47-7-18(1) did not apply retroactively to Rochell's case, and affirmed the Circuit Court's denial of post-conviction relief. View "Rochell v. Mississippi" on Justia Law

A jury found defendant Douglas Walters guilty of grand larceny, and he was sentenced to serve ten years in the custody of the Mississippi Department of Corrections. Walters appealed, arguing that the trial court erred in its application of the grand-larceny statute, in quashing a codefendant’s subpoena, and in admitting unauthenticated hearsay into evidence. Finding no error, the Supreme Court affirmed. View "Walters v. Mississippi" on Justia Law

A jury convicted Robert “Bay Bay” Carson of capital murder, being a felon in possession of a firearm, and conspiracy to commit armed robbery, all of which arose from the 2012 shooting death of Juan Ortiz during an armed robbery. Carson received a life sentence without the possibility of parole for his capital-murder conviction, a ten-year sentence for being a felon in possession of a firearm, and a five-year sentence for conspiracy to commit armed robbery. On appeal, Carson argued that his trial counsel was ineffective for failing to request an instruction regarding the unreliability of accomplice testimony and that there was a “reasonable probability” that there would have been a different outcome at trial if counsel had requested the instruction. He also argued that he was entitled to receive his proposed instruction D-6. Find his arguments to be without merit, the Mississippi Supreme Court affirmed his convictions. View "Carson v. Mississippi" on Justia Law

In 2013, Chaddy Brooks looked through her boyfriend’s phone and saw text messages from another woman. The couple got into an argument that later became physical, and ended with Brooks stabbing the boyfriend in the neck with a kitchen knife. Brooks was convicted of second-degree murder and sentenced to serve forty years in the custody of the Mississippi Department of Corrections. She appealed, arguing that there was insufficient evidence to convict her, and that she received ineffective assistance of counsel. Finding no error, the Supreme Court affirmed. View "Brooks v. Mississippi" on Justia Law

Tamra Stuckey was shot and killed on the couch in Charles Kuebler’s apartment in the early morning hours of June 30, 2010. Tamra had been staying at Kuebler’s apartment for three or four days prior and had shown an unreciprocated romantic interest in Kuebler at that time. The trial court allowed the State to introduce evidence of Kuebler’s flight from custody in July 2011, approximately ten months after he was released on bond. The jury returned a verdict finding Kuebler guilty of deliberate-design murder, and the trial court sentenced him to life in prison. In December 2011, Kuebler filed a motion for a judgment notwithstanding the verdict or, in the alternative, a new trial. After a hearing, the trial court denied the motion in October 2012. Kuebler timely appealed. The Court of Appeals found error with the admission of evidence of Kuebler’s flight and the related jury instruction but held that it was harmless error and affirmed Kuebler’s conviction and sentence. After its review, the Supreme Court found that the trial court committed reversible error by denying Kuebler the opportunity to present his theory of defense, in granting a flight instruction, and by prohibiting Kuebler from offering evidence to rebut the State’s argument that his flight indicated consciousness of guilt. Accordingly, the appellate court was reversed and the matter remanded for a new trial. View "Kuebler v. Mississippi" on Justia Law

Travaris Christian was convicted on two counts of capital murder (underlying felony of robbery); one count of house burglary, conspiracy to commit house burglary, felonious child neglect, and felon in possession of a firearm. Christian appealed, claiming his constitutional rights to confrontation were violated; his convictions were supported by insufficient evidence; and the trial court erred in granting the State an aiding-and-abetting instruction and denying him an abandonment instruction. Finding no merit in any of the issues raised, the Mississippi Supreme Court affirmed Christian’s convictions. View "Christian v. Mississippi" on Justia Law

Donald Bell appealed his conviction and sentence for attempted armed robbery. The jury returned from deliberations and informed the court that they had failed to reach a unanimous decision. Learning the jury was split nine-to-three, the judge instructed them to go back and deliberate one more time. Prior to releasing them for further deliberations, he stated to the jury: "But I don’t want you going back there just being stubborn. Go back there with the seriousness of purpose because you came here to do a job and if we can get a unanimous decision from you, we would like to." Defense counsel immediately moved for a mistrial, arguing that the court’s comment “place[d] undue pressure on those three individuals at this point to make up - come to a decision when their consci[ence] didn’t allow them to issue a conclusion.” That motion was denied. The jury returned its verdict, and Bell was sentenced to a five-year term of imprisonment. The Supreme Court reversed, finding that the trial judge’s comments to the jurors before sending them back for further deliberations were impermissibly suggestive and capable of being interpreted as coercive. The case was remanded for a new trial. View "Bell v. Mississippi" on Justia Law

Brodrick Moody was found guilty of possession of a cell phone while he was incarcerated, for which he was sentenced to ten years, to run consecutively to the sentence he was already serving. Moody appealed, arguing the trial court erred in instructing the jury as to the applicable law and burden of proof. After review, the Supreme Court agreed that the trial court erred in instructing the jury and reversed Moody’s conviction on the cell phone offense, vacated his sentence, and remanded for a new trial. View "Moody v. Mississippi" on Justia Law

Larry Wells was convicted of possession of cocaine with intent to transfer and was sentenced as an habitual offender and a recidivist drug offender to sixty years in the custody of the Mississippi Department of Corrections. Wells appealed his conviction and sentence and the Mississippi Supreme Court affirmed the conviction but remanded the case for resentencing. On remand, the Circuit Court declined to apply the subsequent-drug-offender enhancement and reduced Wells’s sentence from sixty years to thirty years. Wells appealed, contending that the trial court’s refusal to sentence him under the amended version of the statute, which became effective before his resentencing, was erroneous. The Supreme Court affirmed the second sentence, finding that the statutory amendment occurred several years after the commission of the crime and after Wells’s initial sentencing. View "Wells v. Mississippi" on Justia Law