Justia Mississippi Supreme Court Opinion Summaries

Donald Quinn was indicted for the sexual battery of his seventeen-year-old niece, resulting in her pregnancy. The indictment was amended to reflect the crime occurred between July 1, 2015, and May 25, 2016. Pretrial motions included the exclusion of hearsay statements from the victim and her mother, who were unavailable to testify. The trial court allowed limited testimony from Detective Neal and admitted DNA evidence linking Quinn to the child.The Hinds County Circuit Court convicted Quinn, sentencing him to twenty years, with ten years suspended. Quinn's motion for judgment notwithstanding the verdict or a new trial was denied. On appeal, the Court of Appeals reversed the conviction, citing insufficient proof of venue and potential issues with witness testimony and evidence admission.The Supreme Court of Mississippi reviewed the case on certiorari. The court found that the trial court did not err in its rulings. It held that the State sufficiently proved venue through Detective Neal's unobjected-to testimony, which established the crime occurred in Hinds County. The court also found no error in admitting Dr. Schiro's DNA testimony, as he was sufficiently involved in the analysis and report. The amendment to the indictment was deemed proper, as it did not prejudice Quinn's defense. Carolyn Smith's testimony was allowed despite late disclosure, as it did not result in manifest injustice. The court also ruled that the trial court properly handled the State's closing argument and the use of birth certificates to refresh Smith's memory.The Supreme Court of Mississippi reversed the Court of Appeals' decision and reinstated and affirmed the Hinds County Circuit Court's judgment. View "Quinn v. State" on Justia Law

Holly Mitchell was found guilty of second-degree murder and possession of methamphetamine after she shot and killed her husband, Shawn Mitchell, in their home while holding their three-year-old daughter. Holly claimed she acted in self-defense because Shawn was violent and had been using meth. Witnesses testified about the couple's tumultuous relationship, marked by drug use and domestic violence. Holly's defense argued the shooting was accidental, while the prosecution presented evidence of premeditation.The Marion County Circuit Court jury convicted Holly of second-degree murder. During deliberations, the jury expressed confusion about the instructions regarding second-degree murder and manslaughter. The trial court provided clarifications, but Holly's defense did not object to the court's responses. Holly appealed, arguing that the jury instructions were confusing and that her trial counsel was ineffective for not requesting additional instructions on imperfect-self-defense and culpable-negligence manslaughter.The Supreme Court of Mississippi reviewed the case and found no reversible error in the jury instructions, stating they were clear and properly guided the jury's deliberations. The court also noted that the jury ultimately reached a unanimous decision. Regarding the ineffective assistance of counsel claim, the court determined that the issue was best addressed in a post-conviction proceeding due to the lack of a fully developed record on direct appeal.The Supreme Court of Mississippi affirmed Holly's conviction for second-degree murder, dismissing her ineffective assistance of counsel claim without prejudice, allowing her to raise it in a post-conviction proceeding if she chooses. View "Mitchell v. State" on Justia Law

Caleb Corrothers was convicted of two counts of capital murder and one count of aggravated assault after attacking Tonya Clark’s family, resulting in the deaths of her husband and son. The jury sentenced him to death for the murders and life for the assault. Corrothers appealed, but the Supreme Court of Mississippi affirmed his convictions and sentences.Corrothers then sought post-conviction relief, raising multiple issues. The Supreme Court of Mississippi denied all but one claim, which alleged that a female juror had improperly communicated with Clark during the trial. The court granted a hearing on this juror-bias claim. Six years later, an evidentiary hearing was held where Corrothers presented two witnesses, his mother and cousin, who testified they saw the juror mouth “we got it” to Clark. The trial judge found these witnesses not credible due to their personal interest in the case and denied post-conviction relief.Corrothers appealed this decision, arguing that the trial judge improperly disregarded his witnesses' testimony and that his right to compulsory process was denied. The Supreme Court of Mississippi found that the trial judge did not exclude the testimony but rather found it not credible, a determination to which the court must defer. The court also held that the procedural framework established in Gladney v. Clarksdale Beverage Co. applied to Corrothers’s juror-bias claim, and the trial judge did not err in denying additional juror interviews.Ultimately, the Supreme Court of Mississippi affirmed the trial court’s denial of Corrothers’s post-conviction relief, concluding that Corrothers failed to present credible evidence of juror bias. View "Corrothers v. State" on Justia Law

Diamante Myers was charged with shooting into a dwelling and aggravated assault with a deadly weapon. The incident occurred on November 2, 2020, in Picayune, Mississippi, where Myers approached Abasi Bolden, who was cooking in his yard. After a verbal altercation, Myers threw an object at Bolden, leading to a physical fight. Myers later returned with a gun and fired shots, hitting a nearby house and shattering a window. Myers was wearing an ankle monitor, and data from the monitor placed him at the scene. He was arrested nearby, and gunshot residue was found on his hands.The Pearl River County Circuit Court tried Myers in June 2023. The jury found him guilty on both charges. Myers appealed, arguing that the trial court committed plain error by granting jury instruction S-3, which he claimed constituted an impermissible constructive amendment to his indictment. The trial court had denied Myers's motion for a directed verdict after the prosecution rested its case.The Supreme Court of Mississippi reviewed the case. The court held that the language used in jury instruction S-3 did not constitute an impermissible constructive amendment to Myers's indictment. The court found that the instruction did not materially alter the essential elements of the offense or any defense Myers had. Therefore, the trial court's decision to grant the instruction was not plain error. The Supreme Court of Mississippi affirmed the lower court's decision, upholding Myers's convictions. View "Myers v. State of Mississippi" on Justia Law

Lyncoya Ratcliff was convicted of possession of a weapon by a felon and possession of a stolen firearm. He was pulled over by police for a broken headlight, and during the stop, officers found a stolen firearm in the vehicle. Ratcliff denied knowledge of the firearm but admitted ownership of a bag containing ammunition matching the stolen weapon. He was subsequently arrested and convicted on both charges.The Forrest County Circuit Court denied Ratcliff's motion for judgment notwithstanding the verdict, and he appealed. The Court of Appeals affirmed his convictions. Ratcliff then filed a petition for certiorari, which the Supreme Court of Mississippi granted, focusing solely on his conviction for possession of a stolen firearm.The Supreme Court of Mississippi reviewed the case de novo, considering whether the evidence was sufficient to support Ratcliff's conviction for possession of a stolen firearm. The court found that the evidence presented did not exclude the reasonable hypothesis that Ratcliff hid the weapon because he was a convicted felon, not because he knew it was stolen. The court noted that the State failed to provide sufficient evidence of Ratcliff's guilty knowledge that the firearm was stolen, as required by precedent cases such as Barton v. State.The Supreme Court of Mississippi reversed and rendered Ratcliff's conviction for possession of a stolen firearm, finding that the State did not meet its burden of proving guilty knowledge beyond a reasonable doubt. The court did not address Ratcliff's conviction for possession of a weapon by a felon, as it was not raised in the petition for certiorari. View "Ratcliff v. State of Mississippi" on Justia Law

Rudy Toler fired his handgun at four youths while traveling on Highway 90 between Pass Christian and Gulfport in 2021. This led to a high-speed chase during which Toler fired two more shots at pursuing officers. A Harrison County grand jury indicted Toler on ten felony charges, including multiple counts of aggravated assault and failure to stop for law enforcement. In 2023, a jury found Toler guilty on most counts, except for one count of aggravated assault against an officer.The Harrison County Circuit Court sentenced Toler to a total of forty years in prison. Toler appealed, arguing that the evidence was insufficient to support several of the convictions and that the trial court erred in excluding evidence of his peaceful character.The Supreme Court of Mississippi reviewed the case. The court found that the evidence was sufficient to support the convictions for aggravated assault against the officers and one count of aggravated assault against the youths. However, the court determined that the indictment was multiplicitous regarding the four counts of aggravated assault against the youths, as they were based on a single act of firing one shot. The court held that these counts should be merged into one.The Supreme Court of Mississippi affirmed the convictions in part, reversed in part, and remanded the case to the trial court to vacate the sentences for the four multiplicitous counts, merge them into one count, and resentence Toler accordingly. The court also found that the trial court did not abuse its discretion in excluding evidence of Toler’s peaceful character. View "Toler v. State of Mississippi" on Justia Law

In August 2021, Jeremy Childress was involved in an incident where he threatened to commit suicide with a handgun. After being disarmed by a sheriff's deputy, Childress admitted to killing his girlfriend, Michelle Hester, by shooting her in the head. Hester's body was found in a utility room at her residence, with no weapons nearby. Childress claimed the shooting was accidental during an argument.The Harrison County Circuit Court conducted a jury trial, where Childress was convicted of first-degree murder. Childress moved for a directed verdict, arguing insufficient evidence for deliberate-design murder, but the motion was denied. He testified that the shooting was accidental, occurring during a heated argument where Hester allegedly threatened him with a knife and a gun. The jury was instructed on various charges, including first-degree murder, second-degree murder, and manslaughter, but ultimately found Childress guilty of first-degree murder.The Supreme Court of Mississippi reviewed the case, focusing on the sufficiency and weight of the evidence. The court held that the evidence supported the jury's verdict of deliberate-design murder. The court noted that Childress's own admissions and the physical evidence contradicted his claim of an accidental shooting. The court also found that the jury's verdict was not against the overwhelming weight of the evidence, as the jury had reasonably rejected Childress's version of events. Consequently, the Supreme Court of Mississippi affirmed Childress's conviction for first-degree murder. View "Childress v. State of Mississippi" on Justia Law

Lucas Montel Howard, while detained in the Madison County jail, directed his friend Alissia Washington to purchase crack cocaine from a dealer. Law enforcement monitored their phone calls, and when Washington returned with the drugs, she was pulled over and instructed by Howard to hide the cocaine in her vagina. The drugs were later discovered during a search at the police department, leading to Howard and Washington’s indictment on felony drug charges. Washington entered a best-interest plea, while Howard went to trial and was found guilty of possession of cocaine with intent to sell and conspiracy to possess cocaine with intent to sell.The Madison County Circuit Court sentenced Howard as a nonviolent habitual offender and subsequent drug offender to sixty years for possession with intent to sell and twenty years for conspiracy, to run concurrently. Howard appealed, arguing insufficient evidence of intent to sell, a Confrontation Clause violation, double jeopardy, improper admission of Washington’s guilty plea, prosecutorial misconduct, ineffective assistance of counsel, and a sleeping juror issue.The Supreme Court of Mississippi reviewed the case and found that the evidence, including Howard’s phone calls and prior convictions, sufficiently supported the jury’s findings of intent to sell and conspiracy. The court held that the trial court did not abuse its discretion in limiting cross-examination or in handling the sleeping juror issue. The court also found no merit in Howard’s claims of double jeopardy, prosecutorial misconduct, or ineffective assistance of counsel. The cumulative error doctrine was deemed inapplicable as no errors were identified. Consequently, the Supreme Court of Mississippi affirmed Howard’s convictions and sentences. View "Howard v. State of Mississippi" on Justia Law

In the early morning of April 29, 2020, Davonta Wells went to his former girlfriend Taharika Smith's home and, after being denied entry, fired six shots into the residence. Wells was identified as the shooter by Smith, a guest named James Rice, and a neighbor, Pierre Beard. Wells was charged with shooting into an occupied dwelling and possession of a firearm by a convicted felon. He was tried by a jury in the Circuit Court of Lowndes County, Mississippi, and convicted on both counts. Wells was sentenced as a nonviolent habitual offender to ten years for shooting into an occupied dwelling and ten years with four years suspended for possession of a firearm by a convicted felon, to run consecutively.Wells appealed, arguing that the evidence was insufficient to support his conviction for possession of a firearm by a convicted felon because the stipulation of his prior felony was not formally admitted into evidence. The State contended that Wells waived this argument by not objecting at trial and that the stipulation, along with a limiting jury instruction, was sufficient.The Supreme Court of Mississippi reviewed the case and found that Wells was procedurally barred from raising the issue for the first time on appeal. The court also applied the invited error doctrine, noting that Wells had made a tactical decision to stipulate to his prior felony conviction and did not object at trial. The court declined to adopt Wells's proposed requirement for written stipulations to be admitted into evidence, affirming that the current law, which allows for stipulations to be presented through jury instructions, was sufficient. The court held that the stipulation and the limiting instruction provided to the jury met the evidentiary requirements, thus affirming Wells's conviction for possession of a firearm by a convicted felon. View "Wells v. State of Mississippi" on Justia Law

Laquon Fluker was convicted of conspiracy to commit aggravated assault. The incident involved Fluker and others allegedly attacking James Bryant in a prison cell, resulting in Bryant being stabbed. Fluker requested a jury instruction on the lesser-included offense of conspiracy to commit simple assault, which the trial court denied. The jury found Fluker not guilty of aggravated assault but guilty of conspiracy to commit aggravated assault.The Forrest County Circuit Court denied Fluker's request for the lesser-included-offense instruction. The Court of Appeals affirmed this decision, reasoning that the presence of shanks and the nature of the attack indicated an intent to commit aggravated assault. The appellate court held that the evidence did not support a finding of negligence, which would be necessary for a simple assault instruction.The Supreme Court of Mississippi reviewed the case on certiorari. The court found that the trial court erred in denying the lesser-included-offense instruction. The Supreme Court held that, based on the testimony of a co-conspirator, a reasonable jury could have found Fluker guilty of conspiracy to commit simple assault rather than aggravated assault. The court emphasized that the jury should have been allowed to consider whether the agreement among the conspirators was to commit simple assault. Consequently, the Supreme Court reversed the judgments of the Court of Appeals and the Forrest County Circuit Court and remanded the case for a new trial. View "Fluker v. State" on Justia Law