Justia Mississippi Supreme Court Opinion Summaries

Attorney Zachary Jex was hired to defend Jerrell Davis on charges of first-degree murder and aggravated assault. After a mistrial in January 2022, a second trial was scheduled for September 12, 2023. During jury selection, the trial was delayed due to a malfunctioning air conditioner. The next day, Jex negotiated a plea deal for Davis, which included dropping the aggravated assault charge and pleading guilty to two counts of manslaughter. The prosecution agreed, but the judge required Jex to pay the jury costs as a condition for accepting the plea.The Claiborne County Circuit Court issued an order requiring Jex to pay $4,141 for the jury costs. Jex contested this order, arguing that he should not be responsible for the costs. The court treated his argument as a motion to reconsider and denied it. Jex then submitted a written motion to reconsider, which was also denied, leading to his appeal.The Supreme Court of Mississippi reviewed the case. The court found that Jex had voluntarily agreed to pay the jury costs during the plea hearing and that the trial judge had the authority to impose these costs under Rule 3.13 of the Uniform Civil Rules of Circuit and County Court Practice. The court also rejected Jex's arguments that he was under duress, that Rule 3.13 was misapplied, and that the prosecution's actions constituted misconduct.The Supreme Court of Mississippi affirmed the order of the Claiborne County Circuit Court, holding that Jex was required to pay the jury costs as he had agreed during the plea negotiations. View "In Re: Jex" on Justia Law

Eltory Hawkins was convicted by a jury of one count of sexual battery and two counts of fondling his girlfriend’s minor daughter. The Desoto County Circuit Court sentenced him to thirty-five years for sexual battery, ten years for each count of fondling (to run consecutively with the thirty-five years and concurrently with each other), and five years of post-release supervision. Hawkins was also required to register as a sex offender.Hawkins's first trial in March 2022 ended in a mistrial due to juror misconduct. Juror 86 was dismissed for inappropriate behavior, including communicating with other jurors and an audience member. Another juror, Juror 3, disclosed knowing a defense witness but claimed impartiality. The circuit court declared a mistrial, citing potential jury taint. Hawkins's motion to dismiss the case on double jeopardy grounds was denied, and a second trial was scheduled.In the second trial in November 2022, the State presented testimony from several witnesses, including the victims. Lily testified that Hawkins had sexually assaulted her multiple times. Hawkins moved for a directed verdict, arguing insufficient evidence, but the motion was denied. The jury found Hawkins guilty on three counts, and he was sentenced accordingly.The Supreme Court of Mississippi reviewed the case and affirmed the conviction and sentence. The court held that the evidence was sufficient to support the convictions, as Lily's testimony alone was enough for a reasonable juror to find Hawkins guilty beyond a reasonable doubt. The court also found that the jury's verdict was not against the overwhelming weight of the evidence. Lastly, the court ruled that the mistrial in the first trial was justified due to manifest necessity, given the juror misconduct, and did not violate Hawkins's protection against double jeopardy. View "Hawkins v. State" on Justia Law

Jakeviyon Hunter was convicted of first-degree murder and shooting into an occupied vehicle. The incident occurred after Hunter and the victim, Jaquarius Ross, were involved in a traffic stop where marijuana and guns were found in the vehicle. Hunter and Ross were both charged with possession of a controlled substance. Later, Hunter shot Ross multiple times while Ross was in his truck, resulting in Ross's death. The prosecution argued that Hunter's motive was related to the earlier drug charge, which could have negatively impacted Hunter's military career.The Madison County Circuit Court sentenced Hunter to life imprisonment for first-degree murder and five years for shooting into an occupied vehicle. Hunter's post-trial motion was denied by the circuit court. He appealed, arguing that the admission of evidence related to his prior misdemeanor charge was improper and raised several claims of ineffective assistance of counsel.The Supreme Court of Mississippi reviewed the case and found no error in the circuit court's admission of the evidence. The court held that the evidence of Hunter's prior drug charge was admissible under Mississippi Rule of Evidence 404(b) to show motive, intent, plan, and identity. The court also provided a limiting instruction to the jury regarding the use of this evidence. The court found that the evidence was necessary to provide a complete story of the events leading to Ross's murder.Hunter's claims of ineffective assistance of counsel were not addressed on direct appeal because his pro se supplemental brief was filed untimely. The court affirmed Hunter's conviction and sentence, finding no plain error in the admission of the evidence. Hunter may still pursue his ineffective assistance claims under the Mississippi Uniform Post-Conviction Collateral Relief Act. View "Hunter v. State of Mississippi" on Justia Law

Jeffrey Pitts was convicted in February 2021 for sexually battering his four-year-old daughter, AGC. The incident came to light when AGC told her grandmother and mother about inappropriate touching by Pitts. AGC later provided consistent details during a forensic interview and at trial. Pitts was indicted by a Rankin County grand jury and his trial began in February 2021. During the trial, a tender years hearing was held to determine the reliability of AGC's statements, and the trial judge found them reliable. AGC testified in court with a screen obstructing her view of Pitts, which was contested by the defense.The Rankin County Circuit Court allowed the use of the screen, and AGC's testimony was presented to the jury. The jury found Pitts guilty, and the Court of Appeals upheld the conviction. Pitts then petitioned for a writ of certiorari, which was granted by the Supreme Court of Mississippi.The Supreme Court of Mississippi reviewed whether the use of the screen violated Pitts's right to confrontation. The court held that the statutory provision allowing the screen did not require a specific finding of emotional trauma and that all essential elements of confrontation were met. The court emphasized that the statute was enacted under the authority granted by the Mississippi Constitution to protect crime victims' rights. The court found that Pitts's right to cross-examine AGC and observe her demeanor was preserved, and thus, the use of the screen did not violate his constitutional rights. The Supreme Court of Mississippi affirmed the lower court's decision. View "Pitts v. State of Mississippi" on Justia Law

On January 12, 2020, Harold Walker Jr. was involved in a shooting incident at the intersection of Colonial Circle and Old Canton Road in Jackson, Mississippi. Witnesses saw a white car swerve to block a van, and the driver of the white car, identified as Walker, fired multiple shots into the van, killing Bryant Robinson. Walker fled the scene but was pursued by police and later apprehended. Evidence included eyewitness testimonies, security footage, and physical evidence linking Walker to the crime.The Circuit Court of the First Judicial District of Hinds County convicted Walker of first-degree murder, shooting into an occupied vehicle, and felony fleeing from law enforcement. Walker appealed, raising five issues: the trial court's refusal to give a lesser-included-offense instruction for heat of passion manslaughter, the sufficiency and weight of the evidence for the first-degree murder conviction, the admission of his statement to law enforcement, the failure to transcribe the jury instructions conference, and ineffective assistance of counsel.The Supreme Court of Mississippi reviewed the case and found no reversible error. The court held that there was no evidentiary basis for a heat of passion manslaughter instruction, the evidence was sufficient to support the first-degree murder conviction, and the trial court did not err in admitting Walker's statement. The court also found that the failure to transcribe the jury instructions conference did not prejudice Walker, and his counsel was not ineffective. The court affirmed the lower court's judgment. View "Walker v. State of Mississippi" on Justia Law

Raymond Phillips was convicted of attempted aggravated assault after Ronald Brown reported that Phillips had shot at him in Hattiesburg, Mississippi. Brown called 911, and officers arrived to find him distraught. Officer Ianconangelo found a shell casing at the scene, and Officer Truss, who knew Phillips, identified him as the suspect. Phillips was later found driving his truck, which contained a firearm matching the shell casing. Detective Daniels reviewed NOLA camera footage showing Phillips pointing and firing a gun in Brown's direction. The firearm and shell casing were confirmed to match by a forensic examiner.The Forrest County Circuit Court found Phillips guilty of attempted aggravated assault and possession of a weapon by a convicted felon. Phillips was sentenced to twenty years for the assault and ten years for the weapon charge, to be served concurrently. Phillips filed a motion for judgment notwithstanding the verdict or a new trial, which was denied.The Supreme Court of Mississippi reviewed the case. Phillips argued that his Sixth Amendment right to confrontation was violated by the admission of body-camera footage and a search warrant affidavit containing Brown's statements. The court found that the statements on the body-camera footage were non-testimonial as they were made during an ongoing emergency. The court also found that the admission of the search warrant affidavit, which included comments on Phillips's post-Miranda silence, was harmless error given the overwhelming evidence against him. Phillips's claims of cumulative error and ineffective assistance of counsel were also rejected. The court affirmed the lower court's decision, upholding Phillips's conviction. View "Phillips v. State" on Justia Law

In 2012, the victim's mother rekindled a relationship with Cayce William Jones and moved into his house with her two children. After moving in, Jones sexually battered the victim. A grand jury indicted Jones on one count of sexual battery and one count of fondling. A Monroe County jury convicted Jones on both counts.Jones appealed, arguing that he received ineffective assistance of counsel because his trial counsel failed to file post-trial motions. The Monroe County Circuit Court handled the initial trial and conviction.The Supreme Court of Mississippi reviewed the case. Jones contended that his trial counsel was constitutionally ineffective for not filing a motion for a new trial. The court noted that ineffective-assistance-of-counsel claims are sometimes better suited for post-conviction relief proceedings but can be addressed on direct appeal if the record affirmatively shows ineffectiveness or if the parties stipulate that the record is adequate. The court found that the record showed Jones's claim was without merit and addressed it on direct appeal.The court applied the Strickland v. Washington standard, which requires showing that counsel's performance was deficient and that this deficiency prejudiced the defense. Jones failed to demonstrate a reasonable probability that a motion for a new trial would have succeeded. The court noted that the evidence against Jones, including the victim's testimony and expert testimony, countered his arguments. The court concluded that the trial involved conflicting testimony, which the jury properly resolved.The Supreme Court of Mississippi affirmed Jones's conviction and sentence, finding that he did not show that his counsel's decision not to file a motion for a new trial prejudiced his defense. View "Jones v. State of Mississippi" on Justia Law

Zachary Minor was charged with possession of marijuana and trafficking of THC after a package containing these substances was delivered to a residence in Natchez, Mississippi. Agents from the Mississippi Bureau of Narcotics observed the delivery and arrested Mario Hartwell, who retrieved the package. Minor was found in the truck with Hartwell, and evidence from Minor's phone linked him to the package. A grand jury indicted Minor and Hartwell on multiple counts, and Minor's trial was severed from Hartwell's.The Adams County Circuit Court conducted a jury trial, during which the State made several errors, including commenting on Minor's right to remain silent, eliciting inflammatory testimony about the effects of edibles on children, and introducing hearsay evidence from Hartwell. The jury found Minor guilty of possession with intent to distribute and trafficking THC. Minor's motions for a mistrial and a new trial were denied, and he was sentenced to concurrent terms of ten and twenty years.The Court of Appeals affirmed Minor's conviction, finding that the errors were either waived or harmless. However, a dissenting opinion argued that the cumulative effect of the errors warranted a new trial. Minor then petitioned for certiorari.The Supreme Court of Mississippi reviewed the case and found that the cumulative effect of the errors deprived Minor of a fair trial. The court held that the State's actions, including commenting on Minor's right to remain silent, eliciting prejudicial testimony, and introducing inadmissible hearsay, constituted prosecutorial misconduct. The court reversed the Court of Appeals' decision and remanded the case to the circuit court for a new trial. View "Minor v. State of Mississippi" on Justia Law

In November 2019, Sarah and her two minor children lived with her boyfriend, William Jeffrey Knight. Suspecting infidelity, Sarah searched Knight's phone and discovered a pornographic video of her twelve-year-old daughter, Jane. Sarah took the phone to the Petal Police Department, where officers viewed the video and conducted further investigation. Knight was indicted on two counts of child exploitation and one count of touching a child for lustful purposes.The Forrest County Circuit Court held a jury trial, where Knight was found guilty on all counts. He was sentenced to ninety-five years in prison and required to register as a sex offender. Knight filed motions to suppress evidence obtained from his phone, arguing that the search violated his Fourth Amendment rights. The motions were denied, and Knight appealed the decision.The Supreme Court of Mississippi reviewed the case. Knight raised several issues on appeal, including the legality of the warrantless search of his phone, prosecutorial misconduct, the validity of the search warrants, the presentation of false testimony, the proportionality of his sentence, and claims of ineffective assistance of counsel. The court found that the private search doctrine applied to the warrantless search of Knight's phone, as the police did not exceed the scope of Sarah's initial search. The court also determined that the prosecutor's conduct during cross-examination did not amount to misconduct and that the search warrants, despite clerical errors, were valid. The court found no evidence that the State knowingly presented false testimony and ruled that Knight's sentence was within statutory limits.The Supreme Court of Mississippi affirmed Knight's convictions and sentences, finding no cumulative error that would warrant reversal. View "Knight v. State" on Justia Law

In October 2020, Terrance Watts was indicted for the first-degree murder of his half-brother, Yancy Williams, by a grand jury in Hinds County, Mississippi. The incident occurred at a Marathon gas station where Williams was shot in the head by Watts. Surveillance footage and witness testimonies indicated that Williams was intoxicated and aggressive, leading to a physical altercation with Watts. Watts later turned himself in and admitted to the shooting, claiming he panicked.The Hinds County Circuit Court tried Watts in July 2023, where he was convicted of first-degree murder and sentenced to life imprisonment. Watts filed a post-trial motion for a judgment notwithstanding the verdict or a new trial, which was denied by the trial judge. Watts then appealed, raising three issues: the sufficiency of the evidence, the propriety of jury instruction S-4 on deliberate design killing, and the propriety of jury instruction S-2 regarding malice aforethought inferred from the use of a deadly weapon.The Supreme Court of Mississippi reviewed the case and found no error. The court held that the evidence was sufficient to support the conviction, as a rational juror could find each element of first-degree murder beyond a reasonable doubt. The court also found that jury instruction S-4 was proper and did not prejudice Watts, as it accurately stated the law. Additionally, the court held that jury instruction S-2 did not improperly comment on the weight of the evidence, as it was consistent with established legal principles. Consequently, the Supreme Court of Mississippi affirmed the conviction and sentence. View "Watts v. State of Mississippi" on Justia Law