Justia Mississippi Supreme Court Opinion Summaries

After a legislative overhaul of the probation and parole statutes, John Booker, a parole-eligible inmate, requested a case plan pursuant to Mississippi Code Section 47-7-3.1. The Mississippi Department of Corrections (MDOC) denied Booker’s request, stating that the statute did not apply retroactively. The Circuit Court reversed the MDOC’s denial of Booker’s request and found that the statute applied retroactively and that Booker was eligible for a case plan. On December 8, 2016, the Mississippi Supreme Court held that Mississippi Code Section 47-7-3.1 “does not clearly and unequivocally express an intention for retroactive applicability.” Thus, pursuant to Supreme Court precedent, because Booker was convicted prior to July 1, 2014, Booker was not eligible to receive a parole case plan under Section 47-7-3.1. View "Lee v. Booker" on Justia Law

The Circuit Court of Sunflower County directed the Mississippi Department of Corrections to issue Benjamin Cook (pro se) a parole case plan under Mississippi Code Section 47-7-3.1(1), which went into effect on July 1, 2014. The Department of Corrections appealed, arguing that Cook was not entitled to a parole case plan because he was convicted and sentenced prior to July 1, 2014. The sole issue on appeal was whether Cook was entitled to a parole case plan under Section 47-7-3.1(1). Because the Supreme Court held in “Fisher v. Drankus,” (204 So. 3d 1232 (Miss. 2016)) that a parole-eligible inmate convicted and sentenced prior to July 1, 2014 was not entitled to receive a parole case plan under Section 47-7-3.1(1), the decision to issue the parole case plan was reversed and the matter remanded for further proceedings. View "Mississippi Department of Corrections v. Cook" on Justia Law

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

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

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

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

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

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

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

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