Justia Mississippi Supreme Court Opinion Summaries

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

The case involves Joshua Archie, who was convicted of conspiracy and capital murder. The incident occurred on October 26, 2012, when the Ridgeland Police Department responded to a "shots fired" call at Party City. Upon arrival, they found store manager Bobby Adams shot dead. The police were informed by store manager Regina Blake and store employee Undra Ward that a masked gunman with dreadlocks had entered the store, demanded money, and fled with the cash. The police suspected an inside job due to the nature of the crime. Ward later confessed to his involvement and implicated Archie as the gunman.In the lower courts, Archie was found guilty of both conspiracy and capital murder. He appealed the decision, arguing that the trial court erred by denying two of his requested jury instructions, that unauthenticated evidence was wrongfully presented to the jury, that the verdict is against the overwhelming weight of the evidence, and that his trial counsel was ineffective.The Supreme Court of Mississippi affirmed Archie’s conviction. The court found no error in the trial court's decisions, including the denial of Archie's requested jury instructions, the admission of an unauthenticated photograph of Archie, and the verdict's alignment with the weight of the evidence. The court also found that Archie's trial counsel was not ineffective. The court concluded that the evidence against Archie was overwhelming, and any errors in the trial process did not contribute to the verdict. View "Archie v. State" on Justia Law

In this criminal case heard before the Supreme Court of Mississippi, the appellant, Ronald Owens, was convicted by a jury for burglary of a business and was sentenced to serve seven years as a habitual offender. Following the guilty verdict, Owens moved for a Judgment Notwithstanding the Verdict (J.N.O.V.) or, alternatively, for a new trial; both motions were denied by the trial judge. Owens appealed the denial of a new trial, which was affirmed by the Court of Appeals. The Supreme Court of Mississippi granted Owens's petition for certiorari, focusing on the question of whether the trial judge abused his discretion by denying Owens's motion for a new trial.The case centered on a burglary that occurred at a closed pharmacy, with security footage showing an individual leaving the premises carrying a dark bag shortly after the pharmacy's alarm was triggered. A subsequent video from a nearby gas station showed Owens with a bag that matched the one seen in the first video. The prosecution also presented evidence of a stock bottle from the pharmacy found in Owens's home following his arrest.Owens argued that the state presented no evidence linking him to the burglary and that the bag he was seen carrying in the gas station video, which appeared to be red, could not be the same as the black bag seen in the video from the pharmacy. The Supreme Court of Mississippi affirmed the jury's verdict and the trial court's decision, arguing that the jury had enough evidence to rationally conclude that Owens was the individual involved in the burglary. The court held that the verdict was not contrary to the overwhelming weight of the evidence, and thus the trial judge did not abuse his discretion in denying Owens's motion for a new trial. View "Owens v. State of Mississippi" on Justia Law

In this case, Dwan Wakefield aided Byron McBride after McBride committed a car theft, kidnapping, and murder. Wakefield was convicted under Mississippi Code Section 97-1-5 for three counts of aiding McBride in the aforementioned crimes. He appealed to the Supreme Court of Mississippi, arguing that being charged multiple times for being an accessory after the fact for each felony committed by the principal violated the Fifth Amendment's protection against double jeopardy.The court found that, under the unit of prosecution test, the State may charge multiple violations of Section 97-1-5 for each felony committed. The court argued that each felony committed by the principal constitutes a separate unit of prosecution, allowing for multiple convictions under the statute. Wakefield's argument was based on the belief that he committed a single act (giving McBride a ride home) while McBride committed three distinct acts (auto theft, kidnapping, and murder). However, the court disagreed and upheld the judgments of the Court of Appeals and the Madison County Circuit Court.In conclusion, the court held that for the purposes of Mississippi’s accessory after the fact statute, Section 97-1-5, each felony committed by a principal offender constitutes a single unit of prosecution. Therefore, Wakefield was not put in jeopardy by being charged with three separate counts under Section 97-1-5. The court affirmed the lower court's decision. View "Wakefield v. State of Mississippi" on Justia Law

In this case, the Supreme Court of Mississippi affirmed the conviction and sentence of Timothy Marbley for aggravated domestic violence. The case originated from an incident in April 2020, where officers responded to a disturbance at an apartment complex. They found Sherita Lynch, Marbley's girlfriend, with injuries and a trail of blood leading from the apartment. Marbley was not present at the scene. Lynch and Marbley both testified at the trial, providing different accounts of the incident.The court noted that Marbley's counsel had filed a brief asserting that there were no arguable issues for review and complied with the procedures set out in Lindsey v. State when an attorney believes there are no appealable issues. Despite being given an opportunity, Marbley did not file a pro se brief. After reviewing the entire record, the court concurred with Marbley's counsel and found no issues that warranted appellate review.Consequently, the court affirmed Marbley's conviction for aggravated domestic violence and his sentence of ten years, five of which were suspended with nonreporting, supervised probation. View "Marbley v. State of Mississippi" on Justia Law