Justia Mississippi Supreme Court Opinion Summaries

A probation officer improperly induced L.J. Green III to give a statement that led to the discovery of the linchpin evidence used against Green at his robbery trial. While the trial judge suppressed Green’s statement, the judge still admitted evidence that Green possessed the victim’s car keys - evidence wholly derived from Green’s excluded statement. This evidence was admitted over Green’s objection; a jury convicted Green. On appeal, both Green and the State agreed the trial judge wrongly admitted the tainted evidence. Though the State argued the error was harmless, the Mississippi Supreme Court concluded the evidence strongly contributed to Green’s guilty verdicts. “So its admission was not harmless error.” Judgment was therefore reversed and the matter remanded for a new trial. View "Green v. Mississippi" on Justia Law

Ladarius Garrett was convicted by jury of burglary of a hotel room. He claimed his convictions as not supported by sufficient evidence, and that the jury’s verdict was contrary to the overwhelming weight of the evidence. Finding no merit to either claim, the Mississippi Supreme Court affirmed Garrett’s conviction. View "Garrett v. Mississippi" on Justia Law

A grand jury indicted Dwayne Wilson on one count of aggravated assault. The indictment charges that Wilson “unlawfully, willfully, purposely and feloniously attempt[ed] to cause or knowingly caused bodily injury to . . . Stacy Pierce[] by striking him multiple times in the ribs and mouth with a bat, a means likely to produce death or serious bodily harm[.]” Wilson pled not guilty, but he was ultimately convicted on that charge when his first trial ended in a mistrial. On appeal, Wilson contended the second trial violated his constitutional protection against double jeopardy. Additionally, Wilson claimed the verdict was against the overwhelming weight of the evidence. The Mississippi Supreme Court concluded that although the protections against double jeopardy had attached, the trial court did not abuse its discretion by finding manifest necessity to grant a mistrial. Further, the Court found the verdict in the second trial was not against the overwhelming weight of the evidence presented. Accordingly, judgment and conviction were affirmed. View "Wilson v. Mississippi" on Justia Law

Soon after the Mississippi Supreme Court appointed counsel to represent death-row inmate Alberto Garcia in post-conviction proceedings before it challenging his death sentence, the Attorney General preemptively filed in the trial court a “Motion for Notice of and an Opportunity to Be Heard on Requests for Litigation Expenses.” Relying on Mississippi Rule of Appellate Procedure 22(c)(3), the Attorney General asserted her office was entitled to notice and an opportunity to be heard on Garcia’s requests for litigation expenses. Even though Garcia’s counsel had made no such request, the trial court granted the motion. The Supreme Court vacated this ruling: "Under Rule 22(c)(3), the Attorney General is not entitled to notice and an opportunity to be heard on a request for litigation expenses that was never made—and will never be made—because Garcia’s appointed attorneys are not compensated and reimbursed through court-approved expenses but rather through their state employer. ... So the Attorney General’s request was not only premature; it was inapplicable. Thus, the trial court lacked authority to grant the Attorney General’s motion." View "Garcia v. Mississippi" on Justia Law

Courtney Williams appeals her manslaughter conviction. James Williams, his pregnant daughter Courtney, and Courtney’s two children lived with James at James’s residence. James had recently allowed Courtney’s boyfriend, Cymonde “CJ” Sailer, to move in with them. On the night of September 1, 2019, Courtney, her daughter, and CJ were in Courtney’s bedroom watching television. Between 10:30-11:00 p.m., James discovered that CJ had fallen asleep in Courtney’s bed despite an agreement that CJ would sleep in Courtney’s son’s bedroom across the hall. An altercation occurred between James and Courtney. During the altercation, Courtney stabbed James twice in the back. When law enforcement arrived, Courtney advised that her father had attacked her and that she had stabbed her father in the back. One of the law enforcement officers then left to check on James. James was found deceased inside of his vehicle outside of his residence. He was in the driver’s seat, leaned over with his head down. A forensic pathologist who performed James' autopsy found his blood alcohol level was about one and one half times the legal limit. The physician opined the cause of death was “stabbing of the torso” and that the manner of death was homicide. Courtney was indicted and charged with the first-degree murder of James. The Mississippi Supreme Court determined the trial court erroneously refused Courtney's proposed jury instructions related to her right to stand her ground, her conviction and sentence were reversed and the case remanded for a new trial. View "Williams v. Mississippi" on Justia Law

Willie Manning was convicted in 1994 of two counts of capital murder while engaged in commission of a robbery for the murders of Jon Steckler and Tiffany Miller, and was sentenced to death. Manning appealed, asking the Mississippi Supreme Court to allow him to transfer DNA evidence gathered from the crime scene of the murders of Miller and Stecker to a different specialized lab for additional advanced DNA testing. After many years of pursuing options for DNA testing and fingerprint analysis of evidence used against him at trial, pursuant to Mississippi Code Section 99-39-5 (Rev. 2020), the Supreme Court partially granted Manning’s request for post-conviction collateral relief (PCR). Under the Court’s order, Manning proceeded with DNA analysis and fingerprint comparison utilizing the procedures set forth in the statute. For six years, Manning had DNA evidence tested and expert fingerprint analysis performed. After receiving allegedly inconclusive results, Manning appealed here the circuit court’s order denying his motion to transfer the DNA evidence to a different facility for additional DNA testing. The Supreme Court found the circuit court did not abuse its discretion and affirmed the denial of the request for additional testing. View "Manning v. State of Mississippi" on Justia Law

Jelani Miles was convicted of shooting into a vehicle, aggravated assault, and second-degree murder. A circuit court sentenced Miles to five years for shooting into a vehicle, twenty years with five years suspended for aggravated assault, and life for second-degree murder, with all sentences to run consecutively. Miles appealed, and the Mississippi Supreme Court deflected his appeal to the Court of Appeals, which affirmed. The Supreme Court granted Miles’s petition for a writ of certiorari to review the remedy ordered by the Court of Appeals for the trial court’s imprecise and incomplete analysis under Batson v. Kentucky, 476 U.S. 79 (1986). The Supreme Court found the Court of Appeals applied the appropriate remedy by remanding for the trial court to conduct a hearing to complete the second and third steps of the Batson analysis for three challenged venirepersons. Therefore, the judgment of the circuit court's judgment was affirmed in part, and the case was remanded. View "Miles v. Mississippi" on Justia Law

Eugene Bullen was convicted of driving under the influence (DUI), second offense. He appealed to the County Court of Madison County. Following a bench trial, the trial judge found Bullen guilty and sentenced him to thirty days of imprisonment, a two year’s driver’s license suspension, an alcohol and drug assessment, six months supervised probation, eighteen months unsupervised probation, and eighty hours of community service within six months. Aggrieved by that decision, Bullen appealed to the Madison County Circuit Court. The circuit court held that the decision of the county court was supported by substantial evidence and was not manifestly wrong. Bullen then appealed to the Mississippi Supreme Court, arguing the trial court erred by not granting his motion to dismiss for insufficiency of the evidence. Bullen argued the State did not meet its burden to prove beyond a reasonable doubt that he was intoxicated. After review, the Supreme Court held the trial judge was presented with sufficient evidence to find Bullen guilty of violating Mississippi Code Section 63-11-30(1)(a), and accordingly, affirmed. View "Bullen v. Mississippi" on Justia Law

The Catholic Diocese of Jackson, Mississippi filed an interlocutory appeal of its motion to dismiss claims stemming from its termination of Arie Mattheus de Lange. The Diocese argued that, pursuant to the ecclesiastical abstention doctrine found in the First Amendment of the United States Constitution, Lange's employment action be dismissed for lack of subject-matter jurisdiction. The circuit court disagreed and determined that “the resolution of these claims will not require immersion into the faith, discipline and doctrine of the Catholic Church or the Code of Canon Law.” After careful review, the Mississippi Supreme Court concluded the circuit court erred and that the First Amendment demanded dismissal. View "Catholic Diocese of Jackson, Mississippi v. De Lange" on Justia Law

In 2017, Shakeara Harris filed domestic violence charges against Joseph Eubanks. Eubanks was indicted for aggravated domestic violence in June 2017. He was later convicted of simple assault domestic violence in January 2020. Eubanks was sentenced to six months in the custody of the Mississippi Department of Corrections, with six months suspended and 364 days of unsupervised probation. He appealed, raising seven contentions as grounds for appeal. Finding no reversible error however, the Mississippi Supreme Court affirmed Eubanks' conviction. View "Eubanks v. Mississippi" on Justia Law