Justia Mississippi Supreme Court Opinion Summaries

The narrow question presented by this case for the Supreme Court's review was whether the expungement of a misdemeanor, fourth-degree, sexual-offense conviction in another state by the court that entered the conviction entitled the petitioner to relief from his duty to register as a sex offender in Mississippi. The Circuit Court denied the requested relief. But, because expungement of a conviction requires the courts to “restore one to the status occupied prior thereto,” the Supreme Court reversed. View "Stallworth v. Mississippi" on Justia Law

Jamil Chancellor was convicted by jury of armed robbery and armed carjacking. He was sentenced to twenty-five years in the custody of the Mississippi Department of Corrections (MDOC) with ten years suspended on each count and the sentences to run concurrently. He was sentenced to an additional five years pursuant to the gun-enhancement statute. Following the denial of his motion for new trial, Chancellor appealed. Finding no error, the Supreme Court affirmed Chancellor’s convictions and sentences. View "Chancellor v. Mississippi" on Justia Law

Robert Terrell was indicted on twenty counts of mail fraud, conspiracy to commit mail fraud, fraudulent use of identity, conspiracy to commit fraudulent use of identity, timber theft, conspiracy to commit timber theft, false pretense, and conspiracy to commit false pretense. Terrell filed six motions to quash, consolidate, or dismiss various counts. The trial court denied the motions. Terrell appealed, claiming double jeopardy and that the trial court erred by not staying his trial. The State argued that Terrell’s appeal was not properly before the Supreme Court. The Supreme Court agreed and dismissed for lack of jurisdiction. View "Terrell v. Mississippi" on Justia Law

A jury convicted Sherwood Brown of one count of capital murder and two counts of murder and sentenced him to death. The Court granted Brown’s successive petition for post-conviction relief and allowed Brown to proceed in the trial court on his claim that he was mentally retarded and exempt from execution. After a hearing, the trial court held that Brown had failed to prove by a preponderance of evidence that he was mentally retarded. Brown appealed. The Supreme Court affirmed, finding that the trial judge heard the testimony, considered the testimony and evidence presented, followed the applicable case law procedure, and applied the correct legal standard for determining whether Brown was mentally retarded. Giving deference to the trial judge as the finder of fact, the Supreme Court affirmed the trial court's decision. View "Brown v. Mississippi" on Justia Law

Defendant-appellant Lawrence Byrd appealed his conviction for manslaughter and the twenty-year sentence he received. Byrd's appellate counsel certified to the Supreme Court that the record presented no arguable issues for appeal, but filing pro se, defendant argued that he received ineffective assistance of counsel, and that the evidence was insufficient to support his conviction. Finding no merit to any of defendant's issues on appeal, the Supreme Court affirmed his conviction and sentence. View "Byrd v. Mississippi" on Justia Law

Carl Cook was convicted of misdemeanor driving under the influence (“DUI”), first offense. Cook appealed to the County Court of Rankin County. At a trial de novo before the county court, Cook’s counsel moved to dismiss the case, claiming that the investigatory stop which led to Cook’s arrest was an illegal search and seizure because it was based on an anonymous tip that lacked sufficient indicia of reliability. The county court denied the motion and entered a judgment of conviction. Cook then appealed to the Rankin County Circuit Court, and the circuit court affirmed the county court’s conviction. Cook appealed his conviction to the Supreme Court, and the case was assigned to the Court of Appeals. Finding that the investigatory stop was legally justified, the Court of Appeals affirmed the judgment of the Circuit Court of Rankin County. Having granted Cook’s Petition for Writ of Certiorari, the Supreme Court took up the issue of whether the stop violated Cook’s Fourth Amendment right to be free from unreasonable searches and seizures. The Supreme Court concluded the Court of Appeals erred in finding that reasonable suspicion to stop Cook existed in this case. The judgments of the Court of Appeals and the Rankin County Circuit Court affirming Cook’s conviction were both reversed. Without the evidence gathered as a result of the stop, the evidence against Cook was insufficient to sustain a DUI conviction. As such, the Supreme Court reversed and rendered a judgment of acquittal. View "Cook v. Mississippi" on Justia Law

A jury convicted Ronald Hartfield of conspiracy to murder his wife but acquitted him of her murder. The circuit court sentenced Hartfield to twenty years in the custody of the Mississippi Department of Corrections. Hartfield appealed. The Court of Appeals reversed and remanded for a new trial based on the trial court’s exclusion of a coconspirator’s letters offered as statements against her penal interest. The Supreme Court granted the State’s petition for certiorari to address that issue. After review, the Court found that the letters were not against the coconspirator’s penal interest and that they were properly excluded by the trial court. Because the Court of Appeals did not address Hartfield’s arguments on the weight and sufficiency of the evidence and the trial court’s denial of one of Hartfield’s peremptory challenges, the Court ruled on those issues: (1) the trial court’s denial of the peremptory challenge was not clearly erroneous; (2) the evidence was sufficient to support Hartfield’s guilt of conspiracy; and (3) that the verdict of guilt was not against the overwhelming weight of the evidence. Therefore, the Supreme Court reversed the judgment of the Court of Appeals and reinstated and affirmed the judgment of the circuit court. View "Hartfield v. Mississippi" on Justia Law

Jerome Totten was tried and convicted in 2013 for burglary of a dwelling and grand larceny. He was sentenced as a habitual offender to terms of twenty-five and ten years respectively, to be served concurrently. Totten argued on appeal that the State failed to present sufficient evidence that the actual fair market value of the items stolen in the burglary equals or exceeds $500, thereby not supporting the conviction for grand larceny. After review, the Supreme Court held that the circumstantial evidence presented of the value of the items was sufficient for a reasonable jury to infer that the value of the items equaled at least $500. Totten also filed a pro se supplemental brief, challenging his burglary conviction in addition to the conviction for grand larceny. The Supreme Court found no merit to his challenge, and therefore affirmed his convictions. View "Totten v. Mississippi" on Justia Law

In 1982, Antonio Williams pled guilty to two counts of burglary. The trial judge sentenced him to three years' imprisonment on one count, and five years' imprisonment on the other. Then, in 1987, a jury convicted Williams of murder. The trial judge sentenced him to life without parole as a habitual offender under Mississippi Code Section 99-19-81, based on his two prior burglary convictions. The Mississippi Supreme Court affirmed Williams' murder conviction in 1990. In 2012, Williams filed a motion for post-conviction relief, for the first time challenging his burglary convictions. Williams argued that "during the entry of his guilty pleas," he was "denied his Sixth Amendment right to the effective assistance of counsel." Specifically, Williams argued that his counsel failed to inform him of an alleged speedy-trial violation before advising him to plead guilty to one of the counts. Williams also argued that his trial counsel "used coercion by promising [him] a suspended sentence" in the second count, when a suspended sentence allegedly was not statutorily available. Williams concluded that, because of the alleged Sixth Amendment violation, his guilty pleas could not "be considered to have been given voluntarily and intelligently." The circuit judge summarily denied Williams' motion, stating that "it plainly appears from the face of the motion, exhibits and prior proceedings in this case, that [Williams] is not entitled to post-conviction collateral relief." The circuit judge did not elaborate on his reasons for the denial, but the Supreme Court gathered from the language of his order that the denial was on the merits. It was also clear to the Court that from Williams' motion that he was challenging his burglary convictions and not his murder conviction. Rather than reviewing Williams' appeal on the merits, the Court of Appeals found that the circuit court had lacked jurisdiction to entertain Williams' motion, because he had not obtained permission from the Supreme Court prior to filing there. As such, the Court of Appeals found that it, too, lacked jurisdiction and dismissed Williams' appeal. After review, the Supreme Court agreed with Williams that the circuit court had jurisdiction to hear his motion, but found that the circuit judge did not err when he denied it. View "Williams v. Mississippi" on Justia Law

In 1992, Clarence Jones pleaded guilty to murder for which he was sentenced to life in the custody of the Mississippi Department of Corrections. Jones' sentence was indefinitely suspended in 2004 by Governor Musgrove. He was released from prison on parole. In 2008, Governor Barbour granted Jones a pardon. In 2013, Jones moved the Circuit Court to expunge his record because he had received a pardon for his conviction. After a hearing on the matter, the trial court denied Jones' request to have his record expunged, finding that expungements were a creature of statute and that the Legislature has not included "receiving pardons" as grounds for expungement eligibility. Jones then appealed to the Supreme Court. Finding no reversible error in the Circuit Court's analysis, the Supreme Court affirmed. View "Jones v. Mississippi" on Justia Law