Justia Mississippi Supreme Court Opinion Summaries
Articles Posted in Criminal Law
Love v. State of Mississippi
Soweto Ronnell Love pled guilty to two counts of attempting to acquire or obtain possession of a controlled substance by forged prescription and was sentenced as a habitual offender to five years on each count, to run consecutively. Love later filed a pro se Motion for Post-Conviction Collateral Relief (PCR), challenging the voluntariness of his guilty plea. The Tate County Circuit Court dismissed his PCR motion without an evidentiary hearing, finding that Love's plea was voluntary based on the record.On appeal, the Mississippi Court of Appeals affirmed the circuit court's dismissal of Love's PCR motion in a divided decision. The Court of Appeals held that a factual basis existed for Love's plea and that he failed to show his plea was involuntary. Love then filed a pro se motion for rehearing, which was denied, and subsequently filed a petition for writ of certiorari, which the Supreme Court of Mississippi granted.The Supreme Court of Mississippi found that the circuit court erred in dismissing Love's PCR motion without an evidentiary hearing. The court held that Love was misinformed about the minimum penalty he faced as a habitual offender, which amounted to a misapplication of the law and plain error. The court also found that the record did not confirm that Love knowingly pled guilty as a habitual offender. Consequently, the Supreme Court reversed the circuit court's dismissal of Love's PCR motion and the Court of Appeals' decision, remanding the case to the circuit court for an evidentiary hearing to determine whether Love voluntarily pled guilty as a habitual offender. View "Love v. State of Mississippi" on Justia Law
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Criminal Law
Williams v. State of Mississippi
Jatavis Williams was indicted for first-degree murder after the shooting death of Tacari Walker. On November 9, 2020, police responded to a shooting in Columbus, Mississippi, where they found Walker unresponsive. Witnesses indicated that Williams and Walker had been arguing prior to the incident. Williams turned himself in the next day. At trial, Williams claimed self-defense, stating that Walker had threatened him and approached his vehicle aggressively. However, an eyewitness testified that Walker was unarmed and appeared happy before the shooting.The Lowndes County Circuit Court conducted a jury trial from August 22 to August 26, 2022. The jury found Williams guilty of first-degree murder, and he was sentenced to life imprisonment. Williams filed a motion for judgment notwithstanding the verdict or a new trial, which the trial court denied. He then appealed, arguing that the conviction was against the overwhelming weight of the evidence and that the trial court erred in denying his request for a mistrial due to disruptions during the trial.The Supreme Court of Mississippi reviewed the case and affirmed the lower court's decision. The court held that the trial court did not abuse its discretion in denying the mistrial. The disruptions, including an outburst from the victim’s mother and an inappropriate video during a witness's Zoom testimony, were addressed by polling the jury, who indicated they could remain impartial. The court also found that the jury's verdict was not against the overwhelming weight of the evidence, as the jury had properly considered the self-defense claim and found it unconvincing. Therefore, the conviction and sentence were upheld. View "Williams v. State of Mississippi" on Justia Law
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Criminal Law
Williams v. State of Mississippi
On March 7, 2018, a ninth grader named Becky was kidnapped at gunpoint by Jimmy David Williams, a friend of her stepfather, while she was on her way to school. Williams forced Becky into his vehicle, drove to a secluded area, and sexually assaulted her. After the assault, Williams dropped Becky off at school, where she immediately reported the incident to her JROTC instructor. Becky was taken to a hospital for a sexual assault examination, which revealed physical evidence consistent with her account. DNA evidence linked Williams to the crime.The Jackson County Circuit Court convicted Williams of sexual battery and sentenced him to thirty years in prison without the possibility of parole. Williams filed a motion for a new trial or a judgment notwithstanding the verdict, arguing that the conviction was against the overwhelming weight of the evidence due to conflicting testimony. The trial court denied his motion, leading to Williams's appeal.The Supreme Court of Mississippi reviewed the case and upheld the trial court's decision. The court found that the jury had appropriately resolved the conflicting testimonies, including a statement from a social worker suggesting Becky had been gang-raped by multiple men, which Becky denied. The court emphasized that the jury's role is to assess the credibility of witnesses and weigh the evidence. Given the substantial evidence supporting the conviction, including immediate reports by Becky and corroborating DNA evidence, the court concluded that the verdict was not against the overwhelming weight of the evidence. Therefore, the trial court did not abuse its discretion in denying Williams's motion for a new trial. The Supreme Court of Mississippi affirmed Williams's conviction and sentence. View "Williams v. State of Mississippi" on Justia Law
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Criminal Law
Sheely v. State of Mississippi
In 2023, Christopher Sheely was convicted for possessing more than one-tenth gram but less than two grams of methamphetamine. He was sentenced to two years in the custody of the Mississippi Department of Corrections, with the remainder suspended for post-release supervision upon completing a drug and alcohol program. Sheely appealed, arguing that the trial court erred by denying his proposed broken chain of custody jury instruction and that the evidence was insufficient to support the jury’s verdict.The Forrest County Circuit Court initially handled the case, where Sheely was found guilty by a jury. Sheely moved for a directed verdict and later for a judgment notwithstanding the verdict or a new trial, both of which were denied by the trial judge. The trial court found that an adequate chain of custody had been established and that Sheely failed to produce evidence of tampering or substitution of the evidence.The Supreme Court of Mississippi reviewed the case. The court held that the evidence was sufficient to support the jury’s verdict that Sheely knowingly possessed a felony amount of methamphetamine. The court found that the jury was presented with enough evidence to conclude that Sheely was aware of the presence and character of the methamphetamine and that it weighed more than one-tenth of a gram. Additionally, the court held that the trial court did not abuse its discretion in refusing Sheely’s proposed chain of custody jury instruction, as Sheely failed to present evidence of probable tampering or substitution. The Supreme Court of Mississippi affirmed the lower court’s decision. View "Sheely v. State of Mississippi" on Justia Law
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Criminal Law
Jones v. State of Mississippi
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
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Criminal Law
Walker v. State of Mississippi
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
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Criminal Law
Harris v. State of Mississippi
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
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Criminal Law, Government & Administrative Law
Smith v. State
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
Posted in:
Civil Rights, Criminal Law
Turner v. State
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
Posted in:
Criminal Law, Family Law
Morris v. State
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
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Criminal Law