Justia Mississippi Supreme Court Opinion Summaries

On September 7, 2019, Kemond Jones shot Ethan Powell eight times with a 9 mm handgun in the Beechwood Estates neighborhood in Warren County. Powell died from his injuries later that morning. Witness Danny Guice identified Jones as the shooter, and Jones turned himself in later that day. At trial, Guice testified about a prior disagreement between Jones and Powell, and forensic evidence confirmed the cause of death. Jones claimed self-defense, stating Powell slapped him and reached for a gun before he shot him.The Warren County Circuit Court convicted Jones of murder and sentenced him to forty years, with ten years suspended. Jones's motion for a judgment notwithstanding the verdict or a new trial was denied. He appealed, arguing that the trial court erred by allowing improper evidence and that the verdict was against the overwhelming weight of the evidence.The Supreme Court of Mississippi reviewed the case and affirmed the lower court's decision. The court held that the prosecutor's statement during the opening was not evidence and did not prejudice the jury. Additionally, the court found that the jury's verdict was supported by sufficient evidence, including eyewitness testimony from Guice. The court also determined that the Weathersby rule, which requires the acceptance of the defendant's version of events if they are the only eyewitnesses, did not apply because there was conflicting eyewitness testimony from the prosecution. The court concluded that the trial court did not commit reversible error and upheld the conviction and sentence. View "Jones v. State of Mississippi" on Justia Law

Jessica Walker was convicted by a jury of knowingly possessing methamphetamine with a firearm enhancement in the Newton County Circuit Court. The incident occurred on October 21, 2020, when Walker and her then-boyfriend, Richard Buckley, approached a safety checkpoint. Buckley, who initially drove Walker's vehicle, switched seats with her because he lacked a driver's license. During the stop, Deputy Donna Chapman smelled unburned marijuana and found a handgun and a small amount of marijuana in the vehicle. A subsequent search revealed 0.245 grams of methamphetamine between the driver’s seat and the center console. Walker was arrested, while Buckley was released and not investigated further.Walker was indicted on one count of possession of methamphetamine with a firearm enhancement. She pled not guilty, asserting that the methamphetamine belonged to Buckley and that she was unaware of its presence. During the trial, Walker sought to introduce evidence of Buckley’s prior drug-related offenses, but the circuit judge ruled this evidence inadmissible under Mississippi Rule of Evidence 404(b). The jury found Walker guilty, and she was sentenced to six years’ imprisonment, with three years suspended. Her motion for a new trial was denied, leading to her appeal.The Supreme Court of Mississippi reviewed the case and found that the State failed to present sufficient evidence connecting Walker to the methamphetamine. The court noted that while Walker owned the vehicle and was in proximity to the drugs, there were no additional incriminating circumstances to establish constructive possession. The court held that the evidence was insufficient to support Walker’s conviction and reversed and rendered the judgment. View "Walker v. State of Mississippi" on Justia Law

The case revolves around Katherine Harris, who was convicted for aggravated DUI. While driving with a blood-alcohol concentration (BAC) twice the legal limit, Harris crashed into a deputy sheriff and his patrol vehicle, causing severe injuries to the deputy. Before trial, Harris requested public funds to hire her own experts, a toxicologist and an accident reconstructionist, to counter the State’s evidence. However, her blood sample, which she had not requested to be preserved, had been destroyed according to routine procedure nine months after testing. The judge denied her requests for expert funding, finding them broad and theoretical, and Harris failed to articulate concrete reasons how these proposed independent experts would specifically assist her defense.In Mississippi, the discretion to grant or deny an indigent defendant funds to retain an independent expert lies with the trial court. The court found that Harris failed to articulate how her own experts would actually assist her defense. Furthermore, the State’s case did not rely exclusively on these two experts and her BAC. The State called additional witnesses who established the patrol car was clearly visible with its blue lights flashing, and multiple other vehicles successfully passed the patrol car before Harris slammed into it. Witnesses also testified Harris smelled like alcohol, failed a field sobriety test, admitted she had been drinking, and tested positive for alcohol on a portable breathalyzer at the scene.The Supreme Court of Mississippi affirmed Harris’s conviction and sentence, discerning no abuse of discretion in the judge’s denial of Harris’s request for expert funds. Based on the overwhelming evidence supporting Harris’s aggravated DUI conviction, the judge’s discretionary denial, even if erroneous, was not so prejudicial as to render her trial fundamentally unfair. View "Harris v. State of Mississippi" on Justia Law

The case revolves around Christopher Smith, who was convicted of first-degree murder for the death of Nakisa Benson. Smith was initially deemed incompetent to stand trial but was later found competent. During the jury selection process, Smith's counsel exercised ten peremptory strikes on potential jurors, nine of whom were white. The State raised a reverse-Batson challenge, arguing that the strikes were racially motivated. The circuit judge conducted a Batson hearing and disallowed several of Smith's strikes, finding that the reasons provided were not race-neutral.Smith appealed his conviction to the Court of Appeals, arguing that the trial court erred by admitting certain autopsy photographs and by overruling five of his peremptory strikes. The Court of Appeals found no error and affirmed the conviction. Smith then filed a petition for writ of certiorari, contending that the Court of Appeals erred in its Batson analysis with respect to two jurors. He requested that the case be remanded for a proper Batson hearing.The Supreme Court of Mississippi reviewed the case and the Batson challenge. The Court gave great deference to the trial court's findings, stating that it would not overrule a trial court on a Batson ruling unless the record indicated that the ruling was clearly erroneous or against the overwhelming weight of the evidence. The Court found that Smith's counsel had shown a clear pattern of striking jurors because of their race, which was evident from his choice of words during the trial court’s Batson hearing. The Court affirmed the judgments of the Court of Appeals and of the Copiah County Circuit Court, denying Smith's request for a Batson hearing on the two jurors. View "Smith v. State" on Justia Law

Arious Turner, the biological mother of a four-year-old girl (AT), was convicted of kidnapping her daughter. In June 2019, the Bolivar County chancery court had awarded Turner’s former step-mother, Sharetha Kimber, primary physical custody of AT, granting Turner limited visitation rights. In September 2020, Turner failed to return AT to Kimber after the court-ordered visitation period, and AT's whereabouts were unknown for forty-four days. U.S. Marshals located AT in Greenwood, Mississippi, with the help of an informant.The case was initially tried in the Bolivar County Circuit Court, where Turner was indicted for felony kidnapping under Mississippi Code Section 97-3-53. Turner sought a directed verdict after the State rested its case, but the trial judge denied her motion. After deliberation, the jury returned a guilty verdict. The trial judge sentenced Turner to a term of one year in the custody of the Mississippi Department of Corrections, suspended Turner’s incarceration, and reduced her sentence to one year of nonreporting probation. Turner filed a motion for judgment notwithstanding the verdict, or in the alternative, for a new trial, which were denied.The case was then appealed to the Supreme Court of Mississippi. The main issue on appeal was whether the State presented sufficient evidence to convict Turner of kidnapping. The court affirmed the lower court's decision, ruling that a rational juror could reasonably find each element of kidnapping beyond a reasonable doubt based on the evidence presented. The court rejected Turner's argument that the legislature did not intend for Section 97-3-53 to apply to her because she is AT’s natural parent, citing a precedent that a natural parent may be criminally liable for kidnapping their own child when a court decree denies them custody. View "Turner v. State" on Justia Law

Lawrence Morris was accused of raping his younger sister's best friend, Taylor, and was subsequently indicted, tried twice, and found guilty on one count of statutory rape. The incident allegedly occurred during a visit to the Morris family home, where Taylor's father was living at the time. Taylor claimed that while she was asleep, she woke up feeling "weird" and found Morris next to her with her leggings pulled down. She later discovered she was bleeding from her rectum. Taylor's mother immediately picked her up and they reported the incident to the police. A sexual assault exam at a local emergency room revealed a small rectal tear, but no seminal fluid or sperm cells were found in the subsequent forensic testing.The Newton County Circuit Court convicted Morris of statutory rape under Mississippi Code Section 97-3-65(1)(b) for having sexual intercourse with a child under the age of fourteen. Morris was sentenced to eight years, five suspended, three to serve, in the custody of the Mississippi Department of Corrections, followed by five years of supervised probation. He was also ordered to pay a fine and court costs and to register as a sex offender upon his release. Morris's first trial resulted in a mistrial due to a hung jury, and the same jury instructions were given in both trials. Morris appealed his conviction, claiming the jury's verdict was against the sufficiency of and the overwhelming weight of the evidence.The Supreme Court of Mississippi affirmed the conviction. The court found that the evidence was sufficient to support Morris's conviction for statutory rape. The court also determined that the jury's verdict was not against the overwhelming weight of the evidence. The court noted that the jury had the opportunity to weigh the credibility of the witnesses, and their decision to believe Taylor's version of events and deem her more credible could not be reweighed by the court. View "Morris v. State" on Justia Law

Jerry Pittman and Brianna Pierce were indicted for burglary of a dwelling after they broke into a trailer owned by David Parker and stole several items. Pierce took a plea deal and testified against Pittman, who was subsequently convicted. Pittman appealed his conviction, arguing that his trial was constitutionally infirm because evidence of a prior bad act, specifically the theft of power tools in a separate incident, was improperly admitted.Prior to Pittman's trial, the Neshoba County Circuit Court heard a proffer from the State arguing that the evidence of the separate theft was admissible to show absence of mistake under Mississippi Rule of Evidence 404(b). The trial court agreed, noting that it could also show intent to steal, and decided to admit the evidence with a limiting jury instruction.In the Supreme Court of Mississippi, Pittman argued that the admission of evidence of the prior bad act was error and made his trial constitutionally unfair. The court, however, determined that even if the admission of the evidence was an error, it would be harmless. The court noted that the evidence against Pittman was overwhelming, including his own admission of breaking into the trailer and taking items, Pierce's testimony, his written confession, and the stolen items being located in his vehicle. The court concluded that any alleged error did not contribute to the verdict and affirmed Pittman's conviction. View "Pittman v. State of Mississippi" on Justia Law

John Garon Saxton was convicted of aggravated assault for hitting his father-in-law, Toby Melton, in the head with a metal bat. The incident occurred after an altercation between Saxton and his mother-in-law, Vickie Melton, over Saxton disciplining his son. Saxton claimed he slapped Vickie after she pushed him near his injured shoulder, which Vickie denied. Vickie called Toby, but did not tell him about the slap. Saxton testified that he heard Vickie tell Toby about the slap over the phone. When Toby arrived, Saxton told him about the slap, and Toby reacted by pushing Saxton away. Saxton then retrieved a gun from his car, but did not point it at Toby. Saxton claimed that Toby then approached him again, prompting him to grab a bat and hit Toby.The trial court granted two jury instructions submitted by the State and denied a jury instruction submitted by the defense. Saxton appealed, arguing that the trial court erred in its decisions regarding the jury instructions.The Supreme Court of Mississippi affirmed the lower court's decision. The court found no reversible error with the trial court’s rulings on the jury instructions. The court held that while one of the State's instructions was an incomplete statement of Mississippi law, it did not result in a manifest miscarriage of justice, particularly given that Saxton was granted a self-defense instruction. The court also found no merit in Saxton's claim that the trial court erred by denying his proposed instruction, as the content of that instruction was covered elsewhere in the instructions. View "Saxton v. State" on Justia Law

In 2000, Antonio McDowell, a juvenile at the time, was convicted of capital murder and sentenced to life without parole. Following a 2012 Supreme Court ruling in Miller v. Alabama, which deemed mandatory life sentences without parole for juvenile defendants unconstitutional, McDowell's sentence was vacated. The trial court then proceeded with a jury trial for sentencing under Mississippi Code Section 99-19-101. The jury, after considering evidence related to the Miller criteria, was unable to agree on a sentence. The trial judge, instead of imposing a sentence of life, sentenced McDowell to life without parole, a decision that was affirmed by the Court of Appeals.The Mississippi Supreme Court, on certiorari review, found that the trial court's decision to proceed with a jury trial for sentencing under Section 99-19-101 made the section applicable to the entirety of the proceedings. This applicability continued when the jury failed to agree on a sentence. Therefore, the trial court erred by conducting the Miller analysis and sentencing McDowell to life without parole. The Supreme Court reversed the judgments of the Court of Appeals and the trial court and remanded the case back to the trial court for proceedings consistent with its opinion. View "McDowell v. State" on Justia Law

The case revolves around Gail Robinson, who was convicted of heat-of-passion manslaughter for the killing of Bobby Pruitt. The two had a tumultuous relationship, with both having been convicted of domestic violence against each other in the past. On the night of the incident, after a series of altercations, Robinson stabbed Pruitt, who later succumbed to his injuries. Robinson admitted to the stabbing, stating that she was the one who put the knife in Pruitt's chest, not her son who was also present at the scene.Prior to the Supreme Court of Mississippi, the case was heard in the Alcorn County Circuit Court. Robinson was charged with heat-of-passion manslaughter, and the jury was instructed on heat-of-passion manslaughter, self-defense, and reasonable use of force. Robinson was convicted as charged and sentenced to twenty years, with eight years suspended and twelve years to serve in the custody of the Mississippi Department of Corrections. Robinson's post-trial motion was denied by the trial court.In the Supreme Court of Mississippi, Robinson challenged her conviction on two grounds. First, she argued that her trial counsel was ineffective for failing to offer a jury instruction on her right to stand her ground in self-defense. Second, she contended that the State presented insufficient evidence to show she did not act in self-defense. The court affirmed her conviction, stating that the record was not clear enough to address her claim of ineffective assistance of counsel on direct appeal. The court also found that the State's evidence was sufficient to disprove Robinson's claim of self-defense. The court noted that Robinson continued to attack Pruitt past the point of any reasonable fear of imminent death or great bodily harm, and the jury had rejected her self-defense claim after weighing the evidence and credibility of the witnesses. View "Robinson v. State" on Justia Law