Justia Mississippi Supreme Court Opinion Summaries

The circuit court ruled Enoch Oliver could proceed to trial with his malicious-prosecution claim against University of Mississippi Medical Center (UMMC) and two of its law-enforcement officers, Syrone McBeath and David Stewart. Oliver was charged with three misdemeanors: disorderly conduct for failure to comply with the commands of a police officer, resisting arrest, and carrying a concealed weapon. A nol-pros order was signed by the trial court and charges were ultimately dropped against Oliver. Oliver sued civilly, and UMMC, McBeath, and Stewart were served with process; several other officers were not. UMMC, McBeath, and Stewart filed a motion to dismiss, which was joined by the unserved defendants, who specially appeared. The served defendants argued Oliver’s claims were governed by the Mississippi Tort Claims Act (MTCA) and its one-year statute of limitations. The lone exception was the malicious prosecution of the felony claim, because the one-year statute of limitations did not begin to run until that charge was nol-prossed. The unserved defendants’ motion was granted, leaving the remaining claim against the served defendants as the malicious-prosecution claim based on the felony charge. Three-and-a-half years later, UMMC, McBeath, and Stewart filed a motion for summary judgment. UMMC argued, as a state agency, it had not waived sovereign immunity for a malice-based claim; McBeath and Stewart argued Oliver lacked proof they maliciously prosecuted him. Alternatively, all defendants cited the MTCA’s police-protection and discretionary-function immunity. The circuit court denied the defendants’ motion. UMMC, McBeath, and Stewart filed this interlocutory appeal, claiming they were entitled to summary judgment. The Mississippi Supreme Court determined as a matter of law, malice-based torts did not fall under the Mississippi Tort Claims Act’s sovereign-immunity waiver. So Oliver had no malicious-prosecution claim against UMMC or its employees in their official capacity. Oliver also brought malicious-prosecution claims against the UMMC officers in their individual capacity, but the record showed Oliver failed to put forth any evidence the officers acted with malice or lacked probable cause. The Court thus reversed the circuit court’s denial of summary judgment and rendered a final judgment in defendants’ favor. View "University of Mississippi Medical Center v. Oliver" on Justia Law

Groundworx,LLC, appealed a judgment dismissing its breach-of-contract action against the City of Hattiesburg. After reviewing the contract between Groundworx and the City, which Groundworx attached to its complaint, the Mississippi Supreme Court was left with “no doubt” that Groundworx’s complaint was properly dismissed for failure to state a claim. Even taking all of Groundworx’s allegations as true, Groundworx could cite no contractual provision the City allegedly breached. Even if Groundworx expended millions of dollars preparing to perform under the contract, it did so before securing the necessary financing to complete the project. And unfortunately for Groundworx, the contract was clear: if Groundworx did not secure financing by a certain date, the City had the right to terminate the contract. So the Court concluded Groundworx could prove no set of facts to show the City breached the contract. View "Groundworx, LLC v. City of Hattiesburg" on Justia Law

Trevioun Briggs was convicted for robbery and witness-tampering. The Court of Appeals affirmed both convictions. Briggs petitioned the Mississippi Supreme Court for certiorari, which was granted to consider whether his indictment for the witness-tampering count was defective. Finding that the indictment fairly tracked the language of Mississippi Code Section 97-9-115, the Court affirmed the judgment of the Court of Appeals. View "Briggs v. Mississippi" on Justia Law

Adofo Minka was held in direct criminal contempt by the Hinds County Circuit Court for unprofessional and contumacious behavior during the trial of his client which resulted in a mistrial. Minka was fined $100 and ordered to pay the costs of the jury in the amount of $1,350. Minka appealed, arguing: (1) he did not improperly comment during opening statements on a potential sentence his client might receive, which triggered a sua sponte objection from the trial court and was a key basis for the State’s request(s) for a mistrial; (2) his comments did not warrant criminal sanction because counsel have broad latitude during opening statements and closing arguments; (3) the record did not support a finding beyond a reasonable doubt that any of Minka’s comments or conduct constituted criminal contempt; and (4) even if the Mississippi Supreme Court affirmed the trial court’s contempt and sanction order, the monetary fine was $650 more than it should have been; therefore, the sanction amount must be reversed, lowered, and rendered. The Supreme Court found no merit in any of the points of contention argued by Minka on appeal. View "Minka v. Mississippi" on Justia Law

In July 2004, a jury found Tyler Edmonds guilty of the murder of Joey Fulgham, who was his half-sister’s husband. In May 2007, the Mississippi Supreme Court reversed Edmonds’s conviction and remanded the case to the trial court for a new trial due to evidentiary errors. At his new trial in 2008, a jury found Edmonds not guilty. This appeal stemmed from Edmonds’s suit against the State under the Compensation to Victims of Wrongful Conviction and Imprisonment statutes codified in Mississippi Code Sections 11-44-1 to 11-44-15, which permitted a person wrongfully convicted and imprisoned to recover $50,000 for every year of wrongful incarceration. The circuit court concluded that Edmonds was not entitled to compensation because he made a false confession to police officers regarding his involvement with the murder, which equated to a fabrication of evidence. The Supreme Court determined the appropriate interpretation and application of Section 11-44- 7(1)(c), which provided that a plaintiff under the Compensation to Victims of Wrongful Conviction and Imprisonment Act must show he did not “fabricate evidence to bring about his conviction.” The second primary issue before the Court was whether Edmonds’s request for a jury trial should have been granted. On both issues, the Supreme Court held in favor of Edmonds and therefore remanded for further proceedings. View "Edmonds v. Mississippi" on Justia Law

Kale Scott was indicted for one count of aggravated assault, and one count of murder. These charges were brought following a high school graduation party with over 200 attendees; one person was shot in the leg, and another was fatally shot five times in the back. Scott admitted he was the shooter. On appeal of his conviction, he challenged the sufficiency of the evidence presented at trial, and argued the jury’s verdict was against the overwhelming weight of the evidence. Finding no error, the Mississippi Supreme Court affirmed his convictions and sentences. View "Scott v. Mississippi" on Justia Law

A jury found Cortaia Washington guilty of intimidating a witness in violation of Mississippi Code Section 97-9-55. The circuit court sentenced Washington to serve two years in the custody of the Mississippi Department of Corrections, with two months suspended and credit for time served. The circuit court denied Washington’s post-trial motions, and she appealed, challenging the weight of the evidence. Finding no reversible error, the Mississippi Supreme Court affirmed. View "Washington v. Mississippi" on Justia Law

Ronald Shinstock appealed after he was convicted of selling methamphetamine conviction. He argued the trial court should have excluded some of the State’s evidence based on an alleged Fourth Amendment violation. Shinstock conceded he never asserted a Fourth Amendment claim in the trial court. The Mississippi Supreme Court found he forfeited that issue. And the record did not support a finding of plain error. The record also did not sufficiently support Shinstock’s claim of ineffective assistance of counsel. View "Shinstock v. Mississippi" on Justia Law

Timothy Evans was tried and convicted of capital murder with the underlying felony of robbery for the death of Wenda Holling. At the conclusion of the sentencing phase, the jury imposed the death penalty. Evans’s post-trial motions were denied. Evans appealed, raising ten assignments of error. Finding no error, the Mississippi Supreme Court affirmed. View "Evans v. Mississippi" on Justia Law

Melvin Potts appealed his convictions of first-degree murder and motor-vehicle theft, arguing that the trial judge erred by providing additional instructions to the jury, not declaring a mistrial when the jury stated it was deadlocked, and granting and refusing certain jury instructions. Potts further argued insufficient evidence supported his conviction, and that his conviction was against the overwhelming weight of the evidence. Finding no error, the Mississippi Supreme Court affirmed. View "Potts v. Mississippi" on Justia Law