Justia Mississippi Supreme Court Opinion Summaries

Ricky Franklin was convicted on one count of kidnapping and on one count of aggravated assault with a deadly weapon. He was sentenced to thirty years and twenty years, respectively, to run consecutively. A mistrial was entered for one count of forcible rape, and a not-guilty verdict was entered for one count of sexual Franklin was denied his motion for judgment notwithstanding the verdict (JNOV) or, in the alternative, for a new trial. He appealed, arguing the trial court erred: (1) in refusing to instruct the jury on simple assault as a lesser-included offense of aggravated assault, (2) in allowing improper opinion testimony from numerous witnesses concerning whether a bottle could cause serious bodily injury, (3) in allowing prejudicial hearsay statements allegedly made to police; (4) in allowing inflammatory statements in the prosecution's closing argument to violate his right to a fair trial; and (5) in denying Franklin's motion to dismiss for violation of his right to a speedy trial. Upon careful consideration of the trial court record, the Supreme Court reversed and remanded Franklin's conviction of aggravated assault under issue one; the Court did not reach issue two, and affirmed the trial court on all other issues raised on appeal. View "Franklin v. Mississippi" on Justia Law

Martin and Star Pierce were married in Mississippi in 2000, and divorced in Washington state in 2007. Because the Washington court lacked personal jurisdiction over Star, it did not divide the parties' assets. Subsequently, Martin brought an action in Mississippi requesting sale of the parties' Biloxi home and determination of the parties' financial obligations incurred during the marriage. Star filed a counterclaim requesting equitable distribution of the marital assets, alimony, and attorney's fees. The chancellor equitably divided the parties' assets and awarded Star alimony and attorney's fees. Martin appealed the chancellor's judgment, and the Court of Appeals reversed the property division and remanded for further proceedings. On remand, Martin raised two jurisdictional challenges for the first time: (1) he argued that the Washington judgment was res judicata as to Star's claims for equitable distribution and alimony, therefore the chancery court lacked subject-matter jurisdiction to divide the parties' assets.; (2) he also argued that because he never consented to the chancery court's jurisdiction, the chancery court lacked personal jurisdiction to divide his military retirement benefits under the Federal Uniformed Services Former Spouse Protection Act. Upon review, the Supreme Court found no reversible error. Accordingly the Court affirmed the chancery court's decision. View "Pierce v. Pierce" on Justia Law

Minor Zachary Stringer was charged with the murder of his younger brother, Justin. The jury found Zachary guilty of the lesser-included offense of manslaughter. The trial court sentenced Zachary to twenty years, with ten years to serve and ten years of post-release supervision, with five years reporting. Zachary appealed his conviction and sentence, arguing: (1) the trial court erred by allowing multiple gruesome photographs of the victim and the crime scene into evidence; and (2) the trial court erred in denying his motion for judgment notwithstanding the verdict (JNOV). Finding no error, the Supreme Court affirmed Zachary's conviction and sentence. View "Stringer v. Mississippi" on Justia Law

Machon Lyons suffered severe injuries as the result of an automobile accident. The accident occurred when a vehicle operated by Roderick Holliday left the road and collided with a tree. As a result, Lyons obtained a default judgment of $72,500 against Holliday. Holliday's mother, Daisy Lang, insured the vehicle through Direct General Insurance Company of Mississippi. Lang's policy included a provision specifically excluding Holliday from any coverage under the policy. Accordingly, Direct denied coverage for the judgment. Lyons sought a declaratory judgment, asking the Circuit Court to hold that Lang's policy covered the judgment against Holliday. Lyons acknowledged the policy exclusion, but argued that Lang's policy covered the judgment against Holliday because Mississippi law required minimum-liability coverage for all permissive drivers, and because Lang's insurance card failed to mention any permissive-driver exclusions. The circuit court granted summary judgment in favor of Direct, finding that the policy clearly and specifically excluded coverage of Holliday. The Court of Appeals reversed, finding that 63-15-4(2)(a) required liability insurance for all vehicles operated in Mississippi and that Mississippi Code Section 63-15-43 required that the liability insurance policy "pay on behalf of the named insured and any other person, as insured, using any such motor vehicle or motor vehicles with the express or implied permission of such named insured." Although the Court of Appeals reached the right result, it cited as its authority the incorrect statute, so the Supreme Court granted certiorari. The Court concluded the policy exclusion violated Mississippi law: even though Holliday was an excluded driver under the Direct General policy issued to Daisy Lang, the exclusion did not operate to eliminate liability coverage in the minimum amounts required by statute. The trial court's grant of summary judgment was reversed and the case remanded for further proceedings. View "Lyons v. Direct General Insurance Company of Mississippi " on Justia Law

J. C. Williams was convicted of the sale of cocaine. He was adjudicated a habitual offender and a subsequent drug offender, and as such, his sentence was enhanced to forty years in the custody of the Department of Corrections (MDOC), with thirty years to serve and ten years suspended. On appeal, Williams argued that the circuit court "erred in amending the indictment to charge him as a habitual offender." The Court of Appeals rejected that argument and affirmed. Following that denial, Williams filed a pro se petition for the writ of certiorari, which was granted. The Supreme Court found that Williams was provided adequate notice in advance of trial that, upon conviction, the State intended to seek enhanced punishment under Section 99-19-81. However, the State failed to provide adequate notice of its intent to seek enhanced punishment under Section 41-29-147. Thus, the Court affirmed in part and reversed in part the judgments of the Court of Appeals and the Circuit Court and remanded this case for a new sentencing hearing, where Williams was to be resentenced as a habitual offender under Section 99-19-81 only. View "Williams v. Mississippi" on Justia Law

Justin Stewart appealed his convictions of armed robbery and felon in possession of a firearm. Stewart argued that the trial court improperly enhanced his sentence, in violation of his rights against double jeopardy, and erred in denying his motion to suppress out-of-court and in-court identifications. Finding no error, the Supreme Court affirmed. View "Stewart v. Mississippi" on Justia Law

Jeffrey Hill was indicted by a grand jury of possession of a firearm on educational property (the campus of Mississippi State University). In two jury trials, Hill represented himself with the assistance and advice of court-appointed counsel. Hill's first trial resulted in a hung jury. Hill was found guilty of the indicted offense in his second trial and was sentenced to three years in the custody of the Mississippi Department of Corrections (MDOC) and ordered to pay a fine. The trial court denied Hill's post-trial motion for a new trial or, in the alternative, judgment notwithstanding the verdict (JNOV). On appeal to the Supreme Court, Hill challenged his conviction, arguing: (1) his right to counsel and a fair trial under the Sixth Amendment was violated when the trial court refused to allow Hill's court-appointed counsel to withdraw; and (2) the trial court erred when it failed to grant Hill's motion for a new trial on the ground that the verdict was against the overwhelming weight of the evidence. Finding error with regard to the first issue, the Supreme Court reversed Hill’s conviction and remanded the case to the trial court for a new trial. The Court declined to address the second issue. View "Hill v. Mississippi" on Justia Law

Jason Lee Keller appealed his conviction for capital murder stemming from the death of Hat Thi Nguyen. After careful consideration of the trial court record, the Supreme Court found no reversible error and affirmed. View "Keller v. Mississippi" on Justia Law

James Ferguson challenged the sufficiency of the evidence presented against him at trial. He was convicted on aggravated-assault charges. Furthermore, Ferguson argued he received ineffective assistance of trial counsel. Finding no reversible error, the Supreme Court affirmed his convictions. View "Ferguson v. Mississippi" on Justia Law

The Board of Aldermen for the City of Ridgeland denied Baymeadows, LLC's proposed repair plans to correct 1,478 cited code violations, and Baymeadows appealed. Upon review of the Board's decision, the Supreme Court held that the Board did not adequately state its rationale for denying the proposed plans. Therefore, the Court remanded the case back to the Board either to issue Baymeadows a permit or provide an appropriate factual basis for its denial. View "Baymeadows, LLC v. City of Ridgeland" on Justia Law