Justia Mississippi Supreme Court Opinion Summaries

A commercial truck driver was stopped by police in Rankin County, Mississippi, for speeding and following too closely. During the stop, the officer noticed the driver was using paper logs instead of the electronic logs typically required for commercial vehicles, and observed inconsistencies in the logs. The driver, after initial denials, admitted to having over $100,000 in the vehicle, later specifying it was $225,000, which he claimed was for truck repairs or his life savings. The officer obtained consent to search the vehicle and found the cash packaged in multiple envelopes. Further investigation linked phone numbers provided by the driver to ongoing federal drug-trafficking investigations, and a trained narcotics dog showed interest in the cash. The State initiated civil forfeiture proceedings, alleging the money was connected to illegal drug activity.The Circuit Court of Rankin County held a bench trial, heard testimony from law enforcement and an expert in drug trafficking, and issued an order of forfeiture, finding by a preponderance of the evidence that the cash was connected to drug trafficking. The driver appealed, and the Mississippi Court of Appeals, in a split decision, reversed the trial court, concluding the State had not met its burden of proof under the relevant forfeiture statute.The Supreme Court of Mississippi reviewed the case on certiorari. Applying the substantial evidence/clearly erroneous standard, the court found that the trial court’s findings were supported by sufficient circumstantial evidence, including the manner of cash packaging, travel patterns, phone records, and the narcotics dog’s alert. The Supreme Court of Mississippi reversed the judgment of the Court of Appeals and reinstated and affirmed the judgment of the Circuit Court, holding that the State had met its burden to show the currency was more likely than not connected to illegal drug activity and thus subject to forfeiture. View "Chung v. State of Mississippi" on Justia Law

Carlos Jones, Jr. was convicted of attempted aggravated assault after an incident in which he became angry when a neighbor’s visitor honked a car horn, waking him from sleep. Jones confronted his neighbor, Niesha Russell, and after a verbal argument, retrieved a gun from a car, pointed it at Russell, and fired two shots as she fled toward her house. Russell testified that she saw Jones point the gun at her and heard the shots as she ran, though she was not injured. Jones left the scene immediately after the shooting. He later told police that he had fired into the air rather than at Russell.The case was tried in the Circuit Court of Coahoma County, where the State charged Jones with attempted aggravated assault. At trial, the jury heard testimony from Russell and law enforcement. Jones moved for a directed verdict, arguing that the evidence did not show he intended to harm Russell, but the motion was denied. The jury found Jones guilty, and he was sentenced to five years’ imprisonment, with three years to serve and two years of supervised probation. After his motion for a new trial was denied, Jones appealed.The Supreme Court of Mississippi reviewed the conviction. The court held that, when viewing the evidence in the light most favorable to the State, a rational juror could have found beyond a reasonable doubt that Jones intended to shoot Russell, based on the circumstantial evidence that he pointed the gun at her and fired. The court also found that the verdict was not against the overwhelming weight of the evidence, as the jury was entitled to resolve conflicting testimony regarding Jones’s intent. The Supreme Court of Mississippi affirmed the conviction and sentence. View "Jones v. State of Mississippi" on Justia Law

Late one night, a man called police twice, claiming he was being chased, and was found by officers pounding on a homeowner’s door in Beaumont, Mississippi. The man appeared erratic and admitted to drinking. He gave police permission to search his vehicle, which he referred to as “his” car. Inside, officers found a sunglasses case on the dashboard containing a glass pipe and a bag of methamphetamine. While being transported to jail, the man remarked that he “should have gotten rid of that shit before [he] called” the police. Subsequent testing confirmed the substance was methamphetamine, and he was indicted for possession of more than one-tenth gram but less than two grams of a Schedule II controlled substance.The case was tried in the Perry County Circuit Court, where a jury found the defendant guilty of possession of methamphetamine. The court sentenced him to three years in the custody of the Mississippi Department of Corrections. The defendant appealed, arguing that the evidence was insufficient to prove he constructively possessed the methamphetamine and that the verdict was against the weight of the evidence.The Supreme Court of Mississippi reviewed the case. Applying the standard of viewing evidence in the light most favorable to the State, the court held that a rational juror could find the defendant exercised dominion and control over the vehicle and knew about the methamphetamine, especially given his statements and behavior. The court distinguished this case from Ferrell v. State, 649 So. 2d 831 (Miss. 1995), finding additional incriminating circumstances beyond mere proximity. The court concluded that the evidence was sufficient and the verdict was not against the overwhelming weight of the evidence. The conviction and sentence were affirmed. View "Moody v. State of Mississippi" on Justia Law

An employee at a dental clinic within a correctional facility alleged that she was sexually assaulted by an inmate while working in her office. The incident occurred when the inmate entered her office, closed the door, and, according to her testimony, physically restrained and sexually assaulted her. The victim immediately reported the incident to her supervisor and underwent a forensic examination, which revealed DNA evidence consistent with the inmate being the primary contributor. The inmate claimed the encounter was consensual and that he and the victim had a prior relationship, but no evidence supported this assertion.The Circuit Court of Rankin County presided over the trial, during which the jury found the inmate guilty of sexual battery. The court sentenced him to thirty years’ imprisonment as a habitual offender. The defendant filed post-trial motions for a new trial or judgment notwithstanding the verdict, arguing insufficient evidence and that the verdict was against the overwhelming weight of the evidence. The trial court denied these motions, leading to the present appeal.The Supreme Court of Mississippi reviewed the case, applying a de novo standard to the sufficiency of the evidence and an abuse-of-discretion standard to the weight of the evidence. The court held that the evidence, including the victim’s testimony and supporting forensic findings, was sufficient for a rational jury to find guilt beyond a reasonable doubt. The court also found that the verdict was not so contrary to the weight of the evidence as to constitute an injustice. Accordingly, the Supreme Court of Mississippi affirmed the conviction, sentence, and denial of post-trial motions. View "Mayfield v. State of Mississippi" on Justia Law

The case concerns an altercation in an apartment between Sapireya Smith and Denise Neely. Smith, her boyfriend, and her brother shared the apartment, and Neely, who was married to Smith’s brother, entered to help him collect his belongings. A verbal argument between Smith and Neely escalated, culminating in Smith striking Neely in the head with a frying pan. Neely sustained significant injuries, including a fractured orbital bone and a deep laceration, requiring medical treatment and surgery. Smith admitted to throwing the pan but denied beating Neely with it, while another witness, Smith’s boyfriend, claimed not to have seen the fight’s initiation.The Circuit Court of Oktibbeha County conducted a jury trial, during which two of Neely’s treating physicians testified as lay witnesses about Neely’s injuries and treatment. Smith did not object to their testimony at trial. The jury found Smith guilty of aggravated assault, and she was sentenced to ten years in prison. Smith appealed, arguing that the physicians’ testimony constituted improper expert opinion and that her counsel was ineffective for failing to object.The Supreme Court of Mississippi reviewed the case. It found that while some of the treating nurse practitioner’s testimony about potential future complications from Neely’s injuries exceeded the permissible scope of lay opinion, the error was harmless given the overwhelming evidence of aggravated assault. The court also held that the radiologist’s testimony was permissible as lay opinion based on his direct observations and medical records. Regarding ineffective assistance of counsel, the court determined that the failure to object did not amount to constitutional ineffectiveness, as the decisions fell within trial strategy and did not prejudice Smith’s defense. The Supreme Court of Mississippi affirmed Smith’s conviction. View "Smith v. State of Mississippi" on Justia Law

In this case, law enforcement responded to a 2017 homicide in which the victim was found shot in the head, with evidence suggesting robbery and drug involvement. The investigation initially stalled due to lack of leads, but in 2019, new information led to the identification of three suspects, including the appellant. The case remained unresolved until 2021, when the appellant was arrested on unrelated charges and questioned about the murder. During two recorded interviews, the appellant first denied involvement but later admitted to being present and participating in a plan to rob the victim. Other suspects were also interviewed, and ultimately, the appellant and three others were indicted for capital murder. Two co-defendants pleaded guilty to lesser charges, and another pleaded guilty to murder.The case was tried in the Alcorn County Circuit Court. The appellant moved to suppress his statements from both interviews, arguing they were involuntary due to intoxication and coercion, and that his right to counsel was violated. The trial court denied the motion after a suppression hearing, finding the statements voluntary and the right to counsel not unequivocally invoked. At trial, the appellant’s statements and testimony from co-defendants were admitted. The jury convicted the appellant of capital murder, and he was sentenced to life without parole. Post-trial motions for judgment notwithstanding the verdict or a new trial were denied.On appeal, the Supreme Court of Mississippi reviewed claims regarding the denial of the suppression motion, alleged improper witness vouching, the admission of a co-defendant’s prior statement, and ineffective assistance of counsel. The court held that the trial court did not abuse its discretion in admitting the appellant’s statements, found no reversible error in the handling of witness testimony, and determined that any procedural errors were either barred or did not amount to ineffective assistance. The conviction and sentence were affirmed. View "Reyes v. State" on Justia Law

After being suspended from his long-term employment at a Walmart in Southaven, Mississippi, following an incident involving a coworker, the defendant planned and executed a violent attack targeting those he blamed for his suspension. Three days after the suspension, he shot and killed two Walmart managers, set fire to the store, and, during his attempted escape, shot a responding police officer. Surveillance footage captured the events, and the defendant admitted to the killings, arson, and shooting the officer during trial.A jury in the Circuit Court of DeSoto County convicted the defendant of two counts of capital murder and one count of attempted murder. The jury sentenced him to death for each capital murder conviction and to life imprisonment for the attempted murder. The defendant moved for judgment notwithstanding the verdict, which the circuit court denied.On direct appeal, the Supreme Court of Mississippi reviewed several claims: that the trial court erred in admitting evidence from locations other than the crime scene; that the evidence was insufficient to support the capital murder convictions because the arson and murders were not part of one continuous transaction; that the verdicts were against the overwhelming weight of the evidence; and that the court should abandon the M’Naghten Rule as the standard for insanity. The Supreme Court found no error in the admission of evidence, held that the evidence was sufficient to support the convictions under the one-continuous-transaction doctrine, determined the verdicts were not against the overwhelming weight of the evidence, and declined to abandon the M’Naghten Rule. The court also found the death sentences were not disproportionate. Accordingly, the Supreme Court of Mississippi affirmed the convictions and sentences. View "Abram v. State" on Justia Law

Jonathan Harrelson was convicted of statutory rape and sentenced to forty years in the custody of the Mississippi Department of Corrections. The incident involved Harrelson, who was forty-four, picking up two minors, Kendall and Valerie, and taking them to various locations, including a motel and a resort. Kendall testified that Harrelson had sexual intercourse with her at the motel, while Harrelson denied any sexual contact and claimed he believed the girls were older.The case was initially tried in the Jones County Circuit Court, where a jury found Harrelson guilty of statutory rape. Harrelson was sentenced to forty years and required to register as a sex offender. He filed a motion for a new trial, which was denied, leading to this appeal.The Supreme Court of Mississippi reviewed the case. Harrelson argued that prosecutorial misconduct deprived him of a fair trial and that the verdict was against the weight of the evidence. The court found that although the prosecutor's comments about the absence of certain witnesses were improper, Harrelson did not suffer prejudice due to the substantial evidence of his guilt. The court also determined that the weight of the evidence supported the jury's verdict, noting that the testimony of the victim, Kendall, was corroborated by other evidence and that issues of credibility were for the jury to decide.The Supreme Court of Mississippi affirmed Harrelson's conviction and sentence, concluding that the trial was fair and the evidence supported the jury's decision. View "Harrelson v. State of Mississippi" on Justia Law

A man was accused of attempting to commit statutory rape against his thirteen-year-old stepdaughter. The incident occurred in the early morning hours when the child’s mother discovered the man in bed with her daughter, who was nude except for a bra. The mother called 911, and the child was taken to the hospital and later interviewed at a Children’s Advocacy Center. The man was initially indicted on seven counts related to various alleged acts against the child, but all but one count—attempted statutory rape—were dropped or not presented to the jury at trial.The case was tried in the Warren County Circuit Court. Before trial, the court held a hearing to determine whether the child’s recorded interview at the advocacy center could be admitted under the tender years hearsay exception. The court allowed the recording, finding the exception satisfied. During trial, the court also admitted a 911 dispatch report over defense objections regarding hearsay and reliability. The jury heard testimony from the child, her mother, law enforcement, a forensic interviewer, and a nurse examiner. The defense challenged the credibility of the evidence and witnesses, but the jury found the defendant guilty of attempted statutory rape. The trial court sentenced him to fifty years in prison, with thirty years to serve.On appeal, the Supreme Court of Mississippi reviewed claims that the admission of the child’s interview and the 911 report were erroneous, that expert and prosecutorial comments improperly vouched for the child’s credibility, and that cumulative error deprived the defendant of a fair trial. The court held that no reversible error occurred, finding that the defendant’s confrontation rights were not violated, the evidentiary rulings were not plain error, and there was no improper vouching or cumulative error. The conviction was affirmed. View "Cole v. State of Mississippi" on Justia Law

Tony Clark was convicted of capital murder, attempted murder, and possession of a firearm by a previously convicted felon. His death sentence was affirmed by the Mississippi Supreme Court, and the United States Supreme Court denied his petition for writ of certiorari. Clark subsequently filed his first motion for post-conviction relief, claiming intellectual disability and ineffective assistance of counsel, among other issues.The Madison County Circuit Court initially reviewed the case, and the Mississippi Supreme Court affirmed Clark's convictions and sentence. Clark then sought post-conviction relief, which led to the current appeal.The Supreme Court of Mississippi reviewed Clark's motion for post-conviction relief. The court granted the motion in part, remanding the case to the Madison County Circuit Court for an Atkins hearing to determine if Clark is intellectually disabled, which would make him ineligible for execution under the Eighth Amendment. The court found that Clark presented sufficient evidence, including affidavits from medical professionals, to warrant a hearing on his intellectual disability claim. However, the court denied all other claims, including ineffective assistance of counsel related to mitigation evidence, Batson challenges, jury wheel issues, the avoiding arrest aggravator, jurors' racial bias, and jury instructions. The court also rejected Clark's cumulative error argument. The decision was to grant post-conviction relief in part and deny it in part. View "Clark v. State" on Justia Law