Justia Mississippi Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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Terence Jones appealed a Chancery Court's denial of his 2011 petition to disestablish paternity, which relied on Section 93-9-10(3)(c) of the Mississippi Code. Because Jones signed a stipulated agreement of paternity that was approved by court order in 2000, the chancery court properly denied Jones's petition as presented. Accordingly, the Supreme Court affirmed the chancery court's judgment denying Jones's petition. View "Jones v. Mallett" on Justia Law

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Sacory Brown directly appealed his conviction for burglary of a dwelling to the Supreme Court. Brown received a twenty-five year sentence, with eighteen years to serve and seven years suspended (with five of those years on post-release supervision). On appeal, he argued that the Miranda warning he was given before making an inculpatory statement to the police was insufficient because it did not explicitly inform him of his right to stop talking to the police at any time. He also argued that the twenty-five-year sentence was grossly disproportionate in violation of the Eighth Amendment. Furthermore, he argued that the evidence supporting the verdict was legally insufficient and the verdict was against the overwhelming weight of the evidence. Finding no error, the Supreme Court affirmed Brown's conviction and sentence. View "Brown v. Mississippi" on Justia Law

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Defendant Mickey Johnson argued that law enforcement officers gave defective Miranda warnings and coerced his written statement by promising to forego charges against his fiancée. Defendant was ultimately convicted for possession of cocaine. The Supreme Court found defendant's Miranda warnings were not defective, and was not persuaded that the trial court erred in finding defendant voluntarily gave a statement that included his confession. View "Johnson v. Mississippi" on Justia Law

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A jury convicted Eboni White of manslaughter, and the trial judge sentenced her to twenty years in the custody of the Mississippi Department of Corrections (MDOC). White appealed, claiming the trial court erred by: (1) refusing to dismiss her indictment based on certain improper influences on the grand jury; (2) prohibiting her expert witness from giving his opinion at trial on the use of force in self-defense; (3) refusing to instruct the jury on her theory of self-defense; and (4) not allowing her witness to testify because he was in the courtroom during the expert's testimony. Additionally, White challenged the weight and sufficiency of the evidence to support her conviction and argued cumulative error. The Court of Appeals affirmed, finding no error. The Supreme Court granted certiorari on the issues of whether the trial court erred by excluding the witness' testimony and denying White’s jury instructions, the Court found error and reversed for a new trial. View "White v. Mississippi" on Justia Law

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Sweet Valley Missionary Baptist Church filed a complaint against its insurance carrier, Alfa Insurance Corporation. Based on Sweet Valley’s failure to cooperate in discovery, the trial court entered an order of dismissal. Sweet Valley then filed a motion to set aside judgment, or, in the alternative, a motion for new trial. The trial court denied the motion, and, in response, Sweet Valley filed a second complaint against Alfa the same day. The trial court dismissed the second claim based on the expiration of the statute of limitations. Sweet Valley appealed. On rehearing, the Court of Appeals reversed the trial court’s judgment and remanded for further proceedings. Alfa filed a petition for writ of certiorari, and the Supreme Court granted it. Upon review, the Supreme Court held that a motion filed pursuant to Mississippi Rule of Civil Procedure 59(e) tolls the applicable statute of limitations, and it reversed the decision of the trial court. View "Sweet Valley Missionary Baptist Church v. Alfa Insurance Corporation" on Justia Law

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Levi Jenkins was indicted and on two counts of sexual battery and one count of statutory rape against his then-five-year-old niece. He was convicted only of fondling, a lesser-included offense of the second count of sexual battery. Jenkins appealed, raising various issues. Finding his arguments to be without merit, the Supreme Court affirmed the Circuit Court's judgment. View "Jenkins v. Mississippi" on Justia Law

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The trial court granted the defendant’s motion to dismiss because of insufficient service of process. Plaintiff appealed and the Court of Appeals reversed, holding that, even though service of process was improper, good cause existed and the action should not have been dismissed. The Supreme Court granted certiorari because the plaintiff never raised the issue at trial. Because the Court found it was improper to raise this issue for the first time on appeal, it reversed the Court of Appeals' judgment and reinstated and affirmed the judgment of the Circuit Court. View "Lewis v. Forest Family Practice Clinic, P.A." on Justia Law

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In 1987, Johnny Ray Magee was convicted of robbing a liquor store and sentenced to a term of life imprisonment as a habitual offender. The Supreme Court affirmed his conviction in 1989 and dismissed his motion for post-conviction relief in 1992. In 2010, the Court granted Magee’s request to amend his PCR on the basis of his claim of newly discovered evidence of juror misconduct. The Circuit Court held an evidentiary hearing to consider this new evidence. The judge found that, when the prospective jurors were asked whether any of them had family or close friends in law enforcement, a juror’s failure to disclose her belief that a local deputy sheriff was her fourth cousin did not amount to juror misconduct and did not prejudice jury selection. The Court of Appeals affirmed. The Supreme Court granted certiorari on the issues of whether the circuit court erred in finding no juror misconduct and whether the circuit court violated Rule 9.04 of the Uniform Rules of Circuit and County Court by allowing the last-minute testimony of a witness at the evidentiary hearing. The Supreme Court affirmed the circuit court’s denial of postconviction relief, finding that no juror misconduct occurred and that, even if a violation of Rule 9.04 occurred, the error was harmless and the issue was waived due to lack of a defense request for a continuance or mistrial. View "Magee v. Mississippi" on Justia Law

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Gloria Richmond Jackson appealed the Circuit Court Special Judge’s dismissal with prejudice of her petition for judicial review of an election contest, which contested the result of a Democratic primary runoff election. Jackson’s petition was dismissed for lack of jurisdiction, because she failed to attach two attorney certificates to her petition, as required by statute. Upon review, the Supreme Court found that the special judge erred by dismissing Jackson’s petition with prejudice for the nonmerits issue of lack of jurisdiction. Accordingly, the order of dismissal with prejudice was vacated and the case remanded back to the circuit court special judge with instruction to enter an order dismissing this action without prejudice. View "Jackson v. Bell" on Justia Law

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Following his convictions for one count of sexual battery and three counts of gratification of lust, Joe Earl Cole argued on appeal that the trial court erred in admitting hearsay and evidence of alleged prior unindicted acts of sexual misconduct with two of his minor granddaughters. Finding no error, the Supreme Court affirmed. View "Cole v. Mississippi" on Justia Law