Justia Mississippi Supreme Court Opinion Summaries

Derrick Burden was convicted by jury of aggravated assault but acquitted of arson. The trial court sentenced Burden to ten years in the custody of the Mississippi Department of Corrections, with five years suspended and full credit for time served. After sentencing, Burden moved for a directed verdict, which the court denied. Burden also filed a motion for a new trial, which was deemed denied. The Mississippi Supreme Court found the trial court record showed ample evidence in the form of testimony, medical records, and photos, when viewed in the light most favorable to the verdict, was sufficient to sustain an aggravated assault conviction, and the verdict was not against the overwhelming weight of the evidence. Accordingly, judgment was affirmed. View "Burden v. Mississippi" on Justia Law

Alphonso Ward was charged in a multi-offense indictment for automobile burglary and as an habitual offender. Ward was convicted by jury of automobile burglary. At Ward’s sentencing hearing, the State offered evidence attempting to prove Ward’s habitual offender status, but the documents offered were not in the record. Ward was convicted and sentenced as an habitual offender. On appeal, Ward argued: (1) the evidence was insufficient to support the trial court’s finding that Ward was an habitual offender; and (2) the trial court erred when it denied Ward’s motion to dismiss for a violation of his right to a speedy trial. The Mississippi Supreme Court reversed and remanded this case to the trial court to determine whether the specific facts of the instant case justified the finding that good cause existed for the delay in bringing Ward to trial. "If good cause existed, then the trial court should apply the proper Barker analysis. Should it be determined that Ward’s right to a speedy trial has not been violated, then his conviction stands. However, Ward should be resentenced on the substantive crime only." View "Ward v. Mississippi" on Justia Law

Crystal Pernell and Tajarvis Haymon were convicted of two counts of armed robbery (Counts I and II), kidnapping (Count III) and aggravated assault (Count IV). On appeal, Pernell challenged the weight and sufficiency of the evidence used to support her conviction and argued that her request for a lesser offense jury instruction for simple assault should have been granted. Haymon argued that Danzel Williams’s (Danzel) identification of him in a photo lineup was impermissibly suggestive. Finding no error, the Mississippi Supreme Court affirmed. View "Haymon and Pernell v. Mississippi" on Justia Law

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