Justia Mississippi Supreme Court Opinion Summaries

Eddie Minor was convicted of armed robbery and sentenced to serve a term of thirty-five years in the custody of the Mississippi Department of Corrections (MDOC). In 2014, sixteen-year-old Jessie Elbert Taylor Jr. was fatally shot in the back. Police observed Taylor lying in the street, who was at the time conscious; Taylor stated that “he had been robbed by two black males.” Taylor told her that the two males had asked for everything in his pocket. He told them that he did not have anything, and the males pulled out guns and started shooting. Taylor stated that he then turned and started running down the street. Witnesses on the street identified then eighteen-year-old Minor, Emanuel “Little Carl” Latham, and Tyrone Noble as being involved in the shooting. Latham testified against Minor, and based in part on that testimony, Minor was convicted. Minor appealed, arguing both that the evidence was legally insufficient to support his conviction and that the jury’s verdict was contrary to the overwhelming weight of the evidence. Finding no merit in his appeal, the Mississippi Supreme Court affirmed the conviction. View "Minor v. Mississippi" on Justia Law

Samuel Amos was convicted by jury of murder following the shooting death of Marquai Kirkland. Amos was sentenced as a habitual offender to life without the possibility of parole. On appeal, Amos raised two issues: (1) the trial court erred by refusing his proposed accomplice jury instruction; and (2) the trial court erred by denying his motion for a mistrial when the prosecutor referenced a polygraph test. Finding no error, the Mississippi Supreme Court affirmed. View "Amos v. Mississippi" on Justia Law

A jury found Mario Ragland guilty of armed robbery and conspiracy to commit armed robbery. Ragland appealed his convictions, claiming: (1) there was insufficient evidence to support either conviction; (2) the jury verdicts were against the overwhelming weight of the evidence; (3) the trial court erred in allowing accomplice instructions to be submitted to the jury under the evidence of this case, and that those given were either defective or incomplete; and (4) his trial counsel was constitutionally ineffective for failing to object to the accomplice instructions, and for requesting an accomplice instruction on behalf of the defense that was incomplete or incorrect. Finding no reversible error, the Mississippi Supreme Court affirmed. View "Ragland v. Mississippi" on Justia Law

Dr. Ralph Smith Jr. was arrested and indicted in a murder-for-hire plot in 2012. He was eventually committed to the Mississippi State Hospital at Whitfield, where he had been treated for mental illness. Soon after his arrival at Whitfield, the facility’s director recommended Dr. Smith’s illness required continual, involuntary treatment and that he should remain committed at the facility. Dr. Smith disagreed with the recommendation and has contested his commitment to Whitfield at every step. Most recently, Dr. Smith filed a habeas petition and motion for relief from the chancellor’s ruling that ordered his continued inpatient treatment. Dr. Smith argued he was improperly confined and should have been released immediately or discharged to an outpatient facility. The chancellor denied his petition and motion for relief. On appeal, Smith argued his habeas petition was wrongly denied and the Mississippi Department of Mental Health lacked standing to oppose his requests. The Mississippi Supreme Court found that during the pendency of this appeal, Dr. Smith was discharged from Whitfield to an outpatient facility. So the relief he requests in this appeal could no longer be granted; the Court thus dismissed his appeal as moot. View "Smith v. Mississippi Dept. of Mental Health" on Justia Law

Justin Blakeney was convicted of capital murder and sentenced to death after a trial in Jones County before Greene County jurors. On August 10, 2010, twenty-six-year-old Justin Barrett Blakeney called 911, stating that two-year-old Victoria Viner (“V.V.”) had become unresponsive. Blakeney and Lidia Viner, V.V.’s mother, had been dating for approximately eight months at that time. Viner was a noncitizen of the United States. Blakeney and Viner had been living together for approximately six months. V.V. had attended daycare when Blakeney first moved in, but Blakeney had been keeping V.V. at home for around two months because he did not have a job and the couple needed to save money. One day, V.V. complained of headaches and collapsed, prompting a 9-1-1 call. Doctors found V.V. had head injuries consistent with hits to the head. Blakeney was arrested in connection with the child's eventual death. Blakeney was charged with felonious child abuse; Viner was charged with negligence, given probation, and deported. Pre-trial publicity surrounding this case prompted a change in venue. The Mississippi Supreme Court determined reversible error occurred in the denial of Blakeney’s opportunity to present a complete defense, by allowing evidence and testimony obtained from informants working as State agents, and through prosecutorial misconduct. It therefore reversed Blakeney’s conviction and sentence and remanded his case for a new trial on the merits. View "Blakeney v. Mississippi" on Justia Law

Curtis Flowers was indicted on four counts of capital murder with the underlying felony of armed robbery, stemming from the 1996 murders of four employees of Tardy Furniture Store in Winona, Mississippi. After six trials, he was convicted on all four counts of capital murder and sentenced to death. The Mississippi Supreme Court affirmed his convictions and death sentence (“Flowers VI”). Flowers filed a petition for a writ of certiorari with the United States Supreme Court. In Flowers v. Mississippi, 136 S. Ct. 2157 (2016), the Supreme Court granted Flowers’s petition, vacated the Mississippi Supreme Court’s judgment in Flowers VI, and remanded the case to Mississippi for further consideration in light of Foster v. Chatman, 136 S. Ct. 1737 (2016). The Supreme Court decided “Foster” after Flowers VI had been decided. Because the sole issue raised in Foster was whether the prosecution’s use of peremptory strikes was racially motivated in violation of Batson v. Kentucky, 476 U.S. 79 (1986), the Supreme Court’s order pertained to only one issue raised by Flowers in his latest appeal to the Mississippi Court - the Batson issue. Accordingly, the remaining issues addressed by the Court in Flowers VI were not disturbed and the Mississippi Court’s opinion as to the remaining issues was reinstated. After review and further consideration in light of Foster, the Mississippi Supreme Court found no Batson violation and reinstated and affirmed Flowers’s convictions and death sentence. View "Flowers v. Mississippi" on Justia Law

Terry Pitchford was convicted of capital murder in February 2006 and sentenced to death. The Mississippi Supreme Court affirmed his conviction and sentence on direct appeal. Pitchford thereafter filed a motion for leave to file a petition for post-conviction relief (PCR), arguing, inter alia, he had not received a competency hearing in violation of Rule 9.06 of the Uniform Rules of Circuit and County Court Practice. The Supreme Court granted Pitchford’s motion in part and ordered the trial court to conduct a retrospective competency hearing. Before the hearing was conducted, a majority of the Supreme Court held that retrospective competency hearings did not satisfy the purpose of Rule 9.06. Despite this ruling, Pitchford’s retrospective competency hearing took place in May 2015. The trial court found that Pitchford was competent to stand trial in February 2006 and denied Pitchford’s PCR motion. Pitchford appealed, arguing the retrospective competency hearing was: (1) an inadequate remedy for purposes of Rule 9.06; and (2) the State’s experts did not apply the proper standard for competency to stand trial. Finding no merit to these claims, the Supreme Court affirmed the trial court denying the PCR petition. View "Pitchford v. Mississippi" on Justia Law

Kendall Martin was convicted of possession of more than one kilogram of marijuana with intent to distribute. He was sentenced as a subsequent drug offender and as a nonviolent habitual offender to sixty years in the custody of the Mississippi Department of Corrections without the possibility of parole. On appeal, Martin argued that the trial court erred by admitting the evidence because the initial traffic stop was not based on probable cause or reasonable suspicion, and the stop was unreasonably extended in violation of his Fourth Amendment rights. Martin also argues that the State failed to prove that he was a habitual offender under Mississippi Code Section 99-19-81, and that the trial court erred in sentencing him as such. Finding no reversible error, the Mississippi Supreme Court affirmed Martin’s conviction and sentence. View "Martin v. Mississippi" on Justia Law

Sitting as “thirteenth juror,” the Court of Appeals reversed Marlon Little’s convictions and remanded for a new trial, finding the weight of the evidence preponderated heavily against the verdict. Despite its prior language suggesting otherwise, neither the Mississippi Supreme Court nor the Court of Appeals assumes the role of juror on appeal. Nurse practitioner David Ellis was attacked from behind and robbed while leaving his medical clinic. Ellis reacted by swinging his computer bag at the assailant’s head. During the struggle, Ellis fell down, and his attacker also stumbled. Ellis was on the ground when his attacker stuck a gun in Ellis’s face. Ellis saw the man “square in the face” from about three feet away. The man demanded Ellis’s wallet. Ellis complied. And the man fled. When Ellis took the stand, he stated clearly and unequivocally that Little was man who robbed him. The jury found him guilty of armed robbery and possession of a weapon by a convicted felon. He was sentenced to thirty years’ imprisonment for armed robbery and ten years’ for felon-in-possession, with his sentences to run concurrently. After his post-trial motions for judgment not withstanding the verdict and for a new trial were denied, he timely appealed. The appellate court majority found Ellis’s initial identification conflicted with Little’s “actual physical attributes, including age and build.” And because Ellis’s identification of Little as the robber was the only substantive evidence against Little, the majority found a new trial was warranted. The Supreme Court took an opportunity to clarify that neither it nor the Court of Appeals ever acted as “juror” on direct appeal. “We sit as an appellate court, and as such are ill equipped to find facts. [E]ven if we wanted to be fact finders, our capacity for such is limited in that we have only a cold, printed record to review.” The Court found no reason to disturb Little’s guilty verdict. Therefore, the Curt reversed the Court of Appeals and reinstated and affirmed the judgment of the trial court. View "Little v. Mississippi" on Justia Law

Marvin Carver was the passenger in a vehicle not owned by him in which marijuana was found in the rear of the trunk. Although Nicholas Ingram, Carver’s half-brother who had been driving the vehicle, took full ownership of the contraband, Carver was convicted of possession of marijuana. Because the State presented insufficient evidence to support Carver’s conviction, the Mississippi Supreme Court reversed and rendered judgment. View "Carver v. Mississippi" on Justia Law