Justia Mississippi Supreme Court Opinion Summaries

In 2015, William Wells shot and killed Kendrick Brown on the steps of the Madison County Mississippi Courthouse. He was convicted by jury of first-degree murder. On appeal, Wells argued: (1) the trial court violated his due process rights when its in limine orders denied him a fair opportunity to defend himself against the State's accusations; (2) the trial court deprived him a fundamental right to assert his theory of self-defense; (3) the trial court erroneously defined "self-defense,"; (4) the trial court erred in barring Wells' theory of the case as to manslaughter; and (5) the trial court erred in granting the State's motions in limine. Finding no reversible error, the Mississippi Supreme Court affirmed Wells' conviction. View "Wells v. Mississippi" on Justia Law

The City of Meridian filed a petition for forfeiture against Maria Catalan after police found $104,690 in her truck during a traffic stop. Catalan filed a motion to dismiss for failure to state a claim under Rule 12(b)(6) of the Mississippi Rules of Civil Procedure, which the county court granted. The Circuit Court affirmed. The City appealed, and the Court of Appeals affirmed the judgment of the circuit court. Having granted certiorari, the Mississippi Supreme Court agreed with the Court of Appeals’ dissent that the City’s forfeiture petition satisfied the notice pleading requirements of Rule 8 of the Mississippi Rules of Civil Procedure. The Supreme Court also agreed with the Court of Appeals’ dissent that in deciding the Rule 12(b)(6) motion, the county court considered matters outside the City’s petition: the court also considered matters outside the pleadings for purposes of Rule 12(c), which allowed for a judgment on the pleadings. In doing so, the county court in effect converted the Rule 12(b)(6) and/or 12(c) motion into a motion for summary judgment, as provided in Rule 56 of the Mississippi Rules of Civil Procedure. Rule 56(c) of the Mississippi Rules of Civil Procedure requires at least ten days’ notice to both parties that the court is converting the motion, which did not occur in this instance. Accordingly, the Supreme Court reversed the judgment of the Court of Appeals as well as the county court’s order, and remanded the case for further proceedings. View "City of Meridian v. $104,960.00 U.S. Currency et al." on Justia Law

After probation was revoked and he was sentenced to serve the full five years of his suspended sentence, Demario Walker filed a motion for post-conviction relief (PCR). The circuit court dismissed Walker’s petition, and Walker appealed. The Court of Appeals affirmed in part and reversed and remanded in part the judgment of the circuit court. The Mississippi Supreme Court granted certiorari review and held that the Court of Appeals did not err in finding: (1) the circuit court had jurisdiction and authority to revoke Walker’s probation; (2) Walker was afforded due process at his revocation hearing; and (3) revocation of Walker’s probation was proper. However, the Court of Appeals did err in finding that the circuit court’s sentencing Walker to serve the full, five-year term of his suspended sentence was improper. Therefore, in affirming in part and reversing in part, the Supreme Court reinstated and affirmed the circuit court’s judgment. View "Walker v. Mississippi" on Justia Law

Brandy Williams was convicted by jury of the capital murder of Sheriff Garry Welford. He was sentenced to life without the possibility of parole. On appeal, Williams argued the trial court erred by not quashing her indictment, improperly instructing the jury and admitting evidence of her prior crimes. After review, the Mississippi Supreme Court found no reversible error and affirmed. View "Williams v. Mississippi" on Justia Law

Joseph Patrick Brown was convicted of capital murder and sentenced to death in 1994, and his conviction and sentence were affirmed by the Mississippi Supreme Court in 1996. Brown notified the Supreme Court of his intent to file a successive petition for post-conviction relief. Included in that notice was a motion requesting the Court to direct the Circuit Court of Adams County to assume jurisdiction over “discovery matters relevant to Mr. Brown’s successive post-conviction claims.” The Supreme Court unanimously denied that motion on December 17, 2015, finding that “there has been no minimal showing of any need for pre-petition discovery.” Brown’s Motion for Leave to Invoke Discovery and Seek Access Orders in the Circuit Court was thus denied. “The only thing differentiating this motion from the previous request is that Brown now presents [the Supreme] Court with several discovery ‘needs.’ Aside from references to a claim of ineffective assistance of post-conviction counsel, Brown’s motion does not identify with any particularity the issues that he plans to raise in his successive petition. Instead, he claims that so-called ‘pre-petition discovery’ is necessary for him to ‘file a meaningful and constitutionally adequate motion for leave to proceed in the trial court with a petition for post-conviction relief.’” View "Brown v. Mississippi" on Justia Law

Nicholas Johnson appealed his convictions of burglary and attempted armed robbery, claiming the State presented insufficient evidence to identify him as the perpetrator and that the jury found he was the perpetrator contrary to the overwhelming weight of the evidence. Because three witnesses identified Johnson with absolute certainty, the Mississippi Supreme Court affirmed. View "Johnson v. Mississippi" on Justia Law

Jafron Roberts was convicted by jury of kidnapping and statutory rape, but was acquitted him of sexual battery. The Circuit Court imposed the maximum penalty for the kidnapping conviction, thirty years, and sentenced Roberts to thirty-seven years for the statutory rape conviction, to run concurrently with his sentence for kidnapping. Roberts appealed, arguing: (1) the trial court should have granted his motion to suppress his statement to the police; (2) the trial court should have granted his request for production and in camera inspection of medical records; (3) the State’s loss of exculpatory evidence denied his right to due process; (4) the trial court should have excluded the testimony of the State’s DNA expert; and (5) a pre-indictment delay of approximately one year violated his due process rights. Finding no error, the Mississippi Supreme Court affirm Roberts’ convictions. View "Roberts v. Mississippi" on Justia Law

Kevin Boston was convicted of capital murder for the killing of Willie Dean. Boston raised five issues on appeal, one of which was raised by Boston himself in a pro se supplemental brief. In that supplemental brief, Boston argued the trial court erred by granting the State’s “pre-arming instruction.” Finding that the granting of the pre-arming instruction was reversible error, the Mississippi Supreme Court reversed Boston’s conviction and sentence and remanded the case for a new trial. View "Boston v. Mississippi" on Justia Law

Years after his direct appeal was affirmed by the Court of Appeals, Winfred Forkner filed a motion for postconviction relief. The circuit court denied the motion as untimely. Forkner appealed, and the Court of Appeals found that the circuit court was without authority to adjudicate the appeal because Forkner had not obtained the required permission from the Mississippi Supreme Court to file his motion for post-conviction relief in the circuit court. The Court of Appeals also held, erroneously, that the circuit court’s lack of authority to entertain the motion deprived the Court of Appeals of jurisdiction over the appeal. The Court of Appeals then dismissed the appeal, thus allowing the circuit court’s erroneous judgment to stand. The Supreme Court found that because the Court of Appeals did have jurisdiction to consider the lawfulness of the circuit court’s judgment, it erroneously dismissed Forkner’s appeal. Therefore, it reversed the Court of Appeals. Because the circuit court lacked authority to entertain Forkner’s motion, as the Court of Appeals rightly determined, the Supreme Court vacated the circuit court’s judgment. View "Forkner v. Mississippi" on Justia Law

William Ashwell pleaded guilty to burglary and escape. He sought postconviction relief. The Mississippi Supreme Court found, after review of his case, that the circuit court lacked jurisdiction and authority to accept guilty pleas when Ashwell never had been charged with a crime. Accordingly, the Court reversed and vacated Ashwell’s convictions. View "Ashwell v. Mississippi" on Justia Law