Justia Mississippi Supreme Court Opinion Summaries

John Hale was convicted on four counts of sale or transfer of a controlled substance and was sentenced as a habitual offender to serve a total of sixteen years’ imprisonment without the possibility of parole. On appeal, Hale, represented by the Office of Indigent Appeals, argued that the trial court erred in denying his proffered jury instructions on the defenses of involuntary intoxication and entrapment. Hale also has filed a pro se supplemental brief, in which he raised various other issues. Finding no error, the Supreme Court affirmed Hale’s convictions and sentences. View "Hale v. Mississippi" on Justia Law

A jury convicted Archie Quinn of capital murder, and the trial judge sentenced him to life in prison, without the possibility of parole. Quinn appealed to the Supreme Court, arguing: (1) that the jury was incompletely instructed on the elements of the crime; and (2) that he received ineffective assistance of counsel. The Supreme Court found that the trial judge properly instructed the jury and therefore affirmed on that issue. The Court also found that the record in this case did not “affirmatively show” ineffective assistance of counsel. As such, the Court affirmed Quinn’s conviction, but dismissed his ineffective-assistance-of-counsel claim without prejudice to his right to raise it in a proper petition for post-conviction relief. View "Quinn v. Mississippi" on Justia Law

A jury convicted Preston Overton of possession of cocaine and possession of a firearm by a convicted felon. The day before trial, the defense disclosed its intent to call two witnesses, but the circuit judge excluded their testimony as a discovery sanction. Because the record lacked any evidence that the defense made its late disclosure to gain a tactical advantage, the circuit judge erred by excluding Overton’s witnesses. So the Supreme Court reversed Overton’s convictions and remanded this case for a new trial. View "Overton v. Mississippi" on Justia Law

The Hinds County Youth Court found that three-year-old J.T. had been sexually abused by her father, based on a statement she made which could describe either sexual abuse or innocent contact between a father and daughter. Because the State produced no evidence to show that the child’s facially ambiguous statement described abuse, and because the youth-court judge openly and admittedly disregarded the Mississippi Rules of Evidence throughout the adjudication, the Supreme Court reversed and remanded for further proceedings. View "In the Interest of: J.T." on Justia Law

Charles Bester pleaded guilty to forcible rape, and the trial judge sentenced him to life imprisonment. Bester petitioned for post-conviction relief (PCR), arguing that the forcible rape statute allowed only a jury to impose a life sentence, and absent a recommendation from a jury, a trial judge is powerless to impose such a sentence. The trial court and the Court of Appeals rejected this argument and denied Bester’s PCR motion. Agreeing with both courts, the Supreme Court affirmed. View "Bester v. Mississippi" on Justia Law

Steven Lee Boggs appealed his conviction for one count of gratification of lust, arguing that the trial court erred in allowing the State to present improper character evidence. This case arose out of Boggs’s interactions with three minor victims, K.E., S.S. and D.N. The indictment originally included separate charges concerning Boggs’s misconduct toward S.S. and K.E. However, the charge involving S.S. was dismissed on statute-of-limitations grounds prior to trial. Thus, Boggs was tried only for his misconduct toward K.E. Boggs was charged by a separate indictment for an offense involving D.N., but an order nolle prosequi was entered on that indictment in 2011, before the indictment in the instant case was issued. S.S. and D.N. testified for the State in support of Boggs' conviction for his misconduct against K.E. Boggs testified in his own defense and denied any wrongdoing. At the conclusion of trial, the jury found Boggs guilty as charged, and the trial court sentenced him to serve fifteen years in the custody of the Mississippi Department of Corrections. On appeal, Boggs argued that the trial court erred in allowing D.N. and S.S. to testify regarding Boggs’s prior acts of sexual misconduct against them. Finding no reversible error, the Supreme Court affirmed Boggs' conviction. View "Boggs v. Mississippi" on Justia Law

A drug task force was attempting to execute a search warrant on a suspected drug house when gunfire broke out. Several men were standing in front of the house as the taskforce arrived, and, according to the officers, at least one of those men started shooting at the officers and their vehicles. One of the police officers, who was riding in the bed of a pickup truck, stood and returned fire. Ronnie Burton was standing with the man or men who allegedly were shooting at the police, but he did not fire the shots. Instead, he began to run before the shooting started. At some point a bullet struck Burton. The bullet passed through his right shoulder and was never found. Burton did not actually see anyone shoot, and he admitted that he could not identify exactly when he was shot, where he was when he got shot, what caliber of bullet hit him, or who shot him. He conceded that it was possible that one of his armed companions at the house could have fired the shot that hit him, but Burton believed the police shot him. The police officer who returned fire testified that the one person he shot at was not Burton but a man shooting at the police vehicles. Burton did not produce any witnesses or other evidence to contradict the testimony of the officers. Because he was caught fleeing the scene and in possession of a weapon, Burton was arrested. He was released shortly thereafter, when it was determined that he was not the shooter. Burton sued the law enforcement entities that made up the task force as well as the officer who fired his weapon. The Circuit Court rejected the defendants’ claims of Mississippi Tort Claims Act (MTCA) immunity, and found in favor of Burton on most of his claims, awarding him $350,000 for his injuries. Because the Supreme Court found that defendants were immune under the MTCA, it reversed the circuit court and rendered judgment in their favor. View "Hinds County v. Burton" on Justia Law

A drug task force was attempting to execute a search warrant on a suspected drug house when gunfire broke out. Several men were standing in front of the house as the taskforce arrived, and, according to the officers, at least one of those men started shooting at the officers and their vehicles. One of the police officers, who was riding in the bed of a pickup truck, stood and returned fire. Ronnie Burton was standing with the man or men who allegedly were shooting at the police, but he did not fire the shots. Instead, he began to run before the shooting started. At some point a bullet struck Burton. The bullet passed through his right shoulder and was never found. Burton did not actually see anyone shoot, and he admitted that he could not identify exactly when he was shot, where he was when he got shot, what caliber of bullet hit him, or who shot him. He conceded that it was possible that one of his armed companions at the house could have fired the shot that hit him, but Burton believed the police shot him. The police officer who returned fire testified that the one person he shot at was not Burton but a man shooting at the police vehicles. Burton did not produce any witnesses or other evidence to contradict the testimony of the officers. Because he was caught fleeing the scene and in possession of a weapon, Burton was arrested. He was released shortly thereafter, when it was determined that he was not the shooter. Burton sued the law enforcement entities that made up the task force as well as the officer who fired his weapon. The Circuit Court rejected the defendants’ claims of Mississippi Tort Claims Act (MTCA) immunity, and found in favor of Burton on most of his claims, awarding him $350,000 for his injuries. Because the Supreme Court found that defendants were immune under the MTCA, it reversed the circuit court and rendered judgment in their favor. View "Hinds County v. Burton" on Justia Law

Shirley Warren (a/k/a Oliver) was convicted for possession of a controlled substance in a correctional facility. The trial court sentenced her to seven years in the custody of the Mississippi Department of Corrections, with four years suspended and five years of supervised probation. The Supreme Court assigned Warren’s appeal to the Court of Appeals, which reversed it, ruling that Warren’s indictment was fatally defective because it failed to identify the controlled substance that Warren allegedly possessed. The Supreme Court granted the State’s petition for a writ of certiorari to review the judgment of the Court of Appeals, and held that Warren’s indictment sufficiently charged her with possession of a controlled substance in a correctional facility. Furthermore, the Court held that Warren’s other appellate issues lacked merit. The Court reversed the judgment of the Court of Appeals and reinstated and affirmed the judgment of the Circuit Court. View "Warren a/k/a Oliver v. Mississippi" on Justia Law

Aundray Isaac filed his complaint against the State in 2012, seeking compensation for wrongful conviction and imprisonment. During the early morning hours of March 11, 1991, a towel draped over the front door of Shannon Jackson’s apartment caught fire. The towel had been placed there purposefully for privacy, as covering the windows at the top of the door prevented bypassers from seeing up the interior stairwell just beyond the door. That night, Jackson was at home and upstairs with her and Isaac’s two young children. Isaac lived at the apartment with Jackson but had spent most of the night at issue away from the apartment. He knocked on the door after midnight, but, though she was home, Jackson refused to let him in. Jackson testified that the two of them had agreed that “If he was going to continue to live there, he was going to be in before 12:00 or no later than 12:00.” Isaac testified at his wrongful conviction trial that he set the towel on fire, but he maintained that it was an accident. Isaac would be charged with arson, and convicted by jury. In 1994, the Supreme Court determined that the State had failed to prove the malice and willfulness elements of first-degree arson beyond a reasonable doubt and therefore had produced insufficient evidence to support Isaac’s conviction. The Court reversed Isaac’s conviction and discharged him from the custody of the Mississippi Department of Corrections. He then sued for wrongful conviction and imprisonment. The trial court found in favor of the State and dismissed Isaac’s complaint with prejudice. Aggrieved, Isaac appealed. Finding no reversible error, the Supreme Court affirmed. View "Isaac v. Mississippi" on Justia Law