Justia Mississippi Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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Caleb Corrothers was convicted of two counts of capital murder and one count of aggravated assault. For the two capital-murder convictions, he received the death penalty. Corrothers appealed, and the Mississippi Supreme Court affirmed his conviction and death sentence. He petitioned the Court for permission to proceed in the trial court with a motion for post-conviction relief (PCR), citing ten alleged violations of his constitutional rights. For nine of Corrothers’s ten claims, the Court found Corrothers failed to present claims that were both procedurally alive and substantially showed the denial of a state or federal right. But for Corrothers’s claim of juror bias through improper contact, the Court found further proceedings in the trial court were necessary. Thus, the Court granted him leave to proceed in the trial court on this issue only. The rest of the petition was denied. View "Carothers v. Mississippi" on Justia Law

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In 2015, a Covington County jury found Howard Lindsey guilty of two counts of gratification of lust and two counts of sexual battery. On appeal, Lindsey argued that the jury’s verdict was contrary to the overwhelming weight of the evidence. Finding no issue with the verdict, the Supreme Court affirmed Lindsey’s convictions and sentences. View "Lindsey v. Mississippi" on Justia Law

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The Mississippi Department of Corrections (MDOC) appeals the Sunflower County Circuit Court’s decision requiring it to develop a parole case plan for Robert Boyd. In 1986, Boyd was convicted of murder and two counts of aggravated assault. He was sentenced to life imprisonment for the murder, and to four years for each aggravated assault. In May 2001, MDOC released Boyd on parole. But eight years later, he absconded supervision and his parole was revoked. Boyd was released on parole a second time in September 2010, but again violated the terms of his parole and it was revoked in 2013. In July 2015, Boyd asked MDOC to implement a parole case plan for him in accordance with newly enacted Mississippi Code Section 47-7-3.1. When it refused, Boyd moved for judicial review at the Circuit Court, which found that the newly enacted code section could be applied retroactively to Boyd's sentence. Finding that the Circuit Court erred in its analysis of the new law, the Supreme Court reversed and remanded for judgment in favor of MDOC. View "Mississippi Dept. of Corrections v. Boyd" on Justia Law

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Charles Allen, a parole-eligible inmate in the custody of the Mississippi Department of Corrections (MDOC), filed a request pursuant to the administrative review procedure (ARP) that MDOC develop a case plan for him. MDOC denied the request and, after exhausting his administrative remedies, Allen appealed to the Circuit Court of Sunflower County. The circuit court found that Allen was entitled to receive a case plan under an amendment to the Probation and Parole Law. MDOC appealed, arguing that the circuit court lacked jurisdiction over Allen's appeal because it was untimely, and, alternatively, that the Probation and Parole Law did not entitle Allen to receive a case plan. Because MDOC’s argument that the circuit court lacked jurisdiction over Allen’s action was not supported by the record, the Supreme Court did not consider it. The Supreme Court found that the Probation and Parole Law did not entitle Allen to a case plan. Therefore, the Court reversed the decision of the circuit court and rendered a decision in favor of MDOC. View "Mississippi Dept. of Corrections v. Allen" on Justia Law

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The Mississippi Department of Corrections (MDOC) appealed the Sunflower County Circuit Court’s decision requiring it to develop a parole case plan for Jerry Bland. In 1982, Bland pleaded guilty to capital murder, burglary of a dwelling, and uttering a forgery. He was sentenced to life imprisonment for the capital murder, to ten years for the burglary, and to fifteen years for the forgery. Bland first was eligible for parole in October 1998, but he was denied. Since then, Bland had seven more parole hearings. After House Bill 585 went into effect in July 2014, Bland sought a parole case plan pursuant to newly enacted Mississippi Code Section 47-7-3.1. On July 1, 2015, Bland filed his "first step" with MDOC’s Administrative Remedy Program (ARP). In response, MDOC said that House Bill 585 was not retroactive and that it applied only to those offenders sentenced on or after July 1, 2014. Bland then filed a motion for judicial review with the Circuit Court, and the circuit judge reversed MDOC’s decision, finding that Section 47-7-3.1 applied retroactively to offenders sentenced before July 1, 2014. MDOC appealed. Because the Supreme Court found that section 47-7-3.1 did not clearly and unequivocally express an intention for retroactive applicability, the Supreme Court reversed the Circuit Court's judgment. View "Mississippi Dept. of Corrections v. Bland" on Justia Law

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Justin Crockett pled guilty in Panola County Justice Court to headlighting a deer. Crockett appealed his conviction to the Circuit Court of the First Judicial District of Panola County. After a bench trial de novo, that court found Crockett guilty. Crockett then appealed to the Mississippi Supreme Court, arguing solely that there was insufficient evidence to support the conviction. Finding sufficient evidence in the record to sustain Crockett’s conviction, the Supreme Court affirmed. View "Crockett v. Mississippi" on Justia Law

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On the morning of his client’s trial, defense attorney A. Randall Harris tried to withdraw as counsel. When the judge declined his request, Harris told the judge he was “wrong” for doing so, and he “was not going to participate” in the trial. Harris’s refusal to abide by the court’s order forced a continuance. And the judge held him in direct criminal contempt. Harris appealed, but the Supreme Court affirmed the judgment finding Harris guilty of direct criminal contempt and ordering Harris to pay a $100 fine and $1,200 for the cost of the jury venire. View "Harris v. Mississippi" on Justia Law

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Charles Crawford, a Mississippi death row inmate, filed a civil lawsuit, pursuant to 42 U.S.C. 1983, alleging various federal constitutional claims relating to the anesthetic, a compounded version of pentobarbital not approved by the United States Food and Drug Administration (FDA), to be utilized in his execution. After a hearing, the chancery court transferred the case to the Circuit Court of the First Judicial District of Hinds County where the Mississippi Department of Corrections (MDOC) renewed its motion to dismiss. The circuit court granted the motion to dismiss, holding that the Section 1983 claims were the same as or similar to issues which were at the time pending in the Mississippi Supreme Court. Because the Circuit Court of the First Judicial District of Hinds County erroneously dismissed Crawford’s Section 1983 lawsuit on the basis of a factual misapprehension, the Supreme Court reversed and remanded back to that court for further proceedings. View "Crawford v. Fisher" on Justia Law

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Ceasar Johnson was convicted for being a felon in possession of a firearm and for the 2012 murder of Gregory Johnson. He was sentenced to life in prison. He appealed, arguing: (1) because the State’s case rested solely on conjecture and supposition, and because Ceasar presented a reasonable hypothesis consistent with his innocence, the State presented insufficient evidence to convict Ceasar of first-degree murder and being a felon in possession of a firearm; and (2) because the State’s case against Ceasar amounted to nothing more than a hunch, and because Ceasar presented compelling corroborated evidence of a reasonable hypothesis consistent with his innocence, the overwhelming weight of the evidence required a new trial. Finding no reversible error, the Supreme Court affirmed. View "Johnson v. Mississippi" on Justia Law

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A jury convicted James Willie of deliberate design murder. He appealed the conviction, arguing on appeal: (1) that the trial court erred in allowing the State’s ballistic expert to give definitive testimony matching bullets from the crime scene to a gun linked to Willie; (2) that his trial counsel provided ineffective assistance by failing to object to the ballistics testimony; (3) that the jury returned a guilty verdict against the overwhelming weight of the evidence; and (4) that the trial court improperly answered a question submitted by the jury. The Supreme Court held that the judge erred in answering a question posed by the jury during deliberations, and reversed Willie’s conviction and remanded the case to the trial court for further proceedings. View "Willie v. Mississippi" on Justia Law