Justia Mississippi Supreme Court Opinion Summaries
Articles Posted in Criminal Law
Williams v. Mississippi
After review of the facts of this case, the Mississippi Supreme Court concluded that Dillon Williams waived his right to sentencing by jury when he pled guilty to burglary and aggravated assault. For those crimes, a circuit court sentenced him to twenty years for the assault, and twenty-five years for the burglary. The trial court added a twenty-year enhancement to the assault charge because Williams’ victim was an elderly woman. The Supreme Court affirmed the judgment of the trial court that denied Williams’s request for post-conviction relief, and affirmed the judgment of the Court of Appeals that affirmed the trial court. View "Williams v. Mississippi" on Justia Law
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Constitutional Law, Criminal Law
Brown v. Mississippi
A jury found Alvin Brown guilty of manslaughter and four counts of aggravated assault. The circuit court sentenced Brown to twenty years in the custody of the Mississippi Department of Corrections for manslaughter and ten years for each aggravated assault conviction, with the aggravated assault sentences to run concurrently with each other and consecutively to the manslaughter sentence. Brown appealed and the Court of Appeal reversed and remanded for a new trial as to only the aggravated assault convictions due to a variance between the indictment and the jury instructions. Finding no merit as to Brown's appeal of the self-defense instruction, the appellate court affirmed. Because the Court of Appeals’ affirmed the trial court’s decision to give the State’s imperfect self-defense instruction, which conflicted with controlling caselaw affirming the refusal of imperfect self-defense instructions when requested by defendants, the Supreme Court also reversed Brown’s manslaughter conviction. View "Brown v. Mississippi" on Justia Law
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Constitutional Law, Criminal Law
Routh v. Mississippi
The Mississippi Supreme Court concluded that the trial court record in this case supported a criminal-contempt finding beyond a reasonable doubt. Christopher Scott Routh was found in direct criminal contempt after he disrespected the court -specifically by standing up to dispute a judge’s bond ruling after the bond hearing had been concluded and despite being directed by the judge to sit down and make any further argument by written motion. View "Routh v. Mississippi" on Justia Law
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Constitutional Law, Criminal Law
Wilcher v. Mississippi
Janice Wilcher appealed her conviction for retaliation against a public servant for making a false representation of rape against Deputy Michael Townsend of the Scott County Sheriff’s Department. Wilcher claimed Section 97-9-127 was unconstitutionally vague. Wilcher further claimed the State failed to prove that Deputy Townsend suffered any actual harm, as alleged in the indictment. Finding no merit in either issue, the Mississippi Supreme Court affirmed. View "Wilcher v. Mississippi" on Justia Law
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Constitutional Law, Criminal Law
Shelton v. Mississippi
Tameshia Shelton was convicted by jury of the murder of Daniel Young. After the trial, Shelton filed a motion for judgment notwithstanding the verdict or in the alternative for a new trial. The trial court denied the motion. Shelton appealed, raising three issues: (1) challenging the sufficiency of the evidence; (2) alleging the verdict was against the weight of the evidence; and (3) alleging the trial court erred by denying her requested two-theory jury instruction. Finding no error, the Supreme Court affirmed her conviction. View "Shelton v. Mississippi" on Justia Law
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Constitutional Law, Criminal Law
Jackson v. Mississippi
Pro se appellant David Jackson appealed the Circuit Court’s denial of his Motion for Transcripts and Records. The Court of Appeals dismissed Jackson’s appeal for lack of jurisdiction. On certiorari review, the Supreme Court found the Court of Appeals correctly recognized the issue was lack of subject matter jurisdiction, but it was the trial court that lacked jurisdiction, not the appellate court. So the Supreme Court modified the Court of Appeals’ disposition and affirmed. View "Jackson v. Mississippi" on Justia Law
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Constitutional Law, Criminal Law
Martin v. Mississippi
Eugene Martin was convicted of shooting into a dwelling and sentenced as a habitual offender under Section 99-19-81. He claimed one of his two prior qualifying felony convictions resulted in a sentence of less than one year. Section 99-19-81 authorizes the State to seek increased punishment for those charged with a felony offense after having twice been convicted of prior felonies. But for this statutory enhancement to apply, the State must prove each of the defendant’s prior felony convictions resulted in a sentence of one or more years in a state or federal prison. If the State sought enhanced sentencing, and the requirements were met, Section 99-19-81 mandated the court sentence the defendant to the maximum term of imprisonment for the subject offense - in this case ten years. Martin argued he was wrongfully subjected to the sentencing enhancement. After review, the Supreme Court agreed, affirmed Martin’s conviction for
shooting into a dwelling, but reversed and remanded for resentencing. View "Martin v. Mississippi" on Justia Law
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Constitutional Law, Criminal Law
Spore v. Mississippi
Hinds County Assistant Public Defender attorney Greg Spore appealed the order finding him in direct criminal contempt by Judge Jeff Weill Sr. of the Hinds County Circuit Court for displaying willful, contemptuous behavior that interfered with the orderly administration of justice. Spore represented Jeremy Cowards in an adjudication hearing, following the violation of his probation. Cowards had been indicted for house burglary and was ordered to Regimented Inmate Discipline (RID). After the pronouncement of guilt, Judge Weill asked whether the defense had any argument for the court to consider for sentencing. "Simply trying to make [his] record" on behalf of Cowards, Spore kept talking despite the trial court's admonition to stop. Finding that the record supported the trial court’s order beyond a reasonable doubt, the Supreme Court affirmed. View "Spore v. Mississippi" on Justia Law
Lenoir v. Mississippi
A jury convicted Laterrence Lenoir of two counts of armed robbery and one count of conspiracy to commit armed robbery. Lenoir appealed, arguing the jury had insufficient evidence to determine that he committed the crime or, alternatively, that his motion for a new trial should have been granted. After review, the Supreme Court disagreed and affirmed his convictions. View "Lenoir v. Mississippi" on Justia Law
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Constitutional Law, Criminal Law
Hales v. Mississippi
Sam Hales was convicted and sentenced to serve a term of twenty-five years in the custody of the Mississippi Department of Corrections (MDOC) for one count of sexual battery and fifteen years for one count of touching a child for lustful purposes, for a total of forty years, to be served day for day. Hales argued on appeal that the trial court erred in denying his motion for judgment notwithstanding the verdict (JNOV) because the jury’s verdict was against the overwhelming weight of the evidence. Finding no error, the Supreme Court affirmed Hales’s convictions and sentences. View "Hales v. Mississippi" on Justia Law
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Constitutional Law, Criminal Law