Justia Mississippi Supreme Court Opinion Summaries

Erik Hollie walked into a pawn shop in Wesson, Mississippi, and killed the owner because he didn’t follow "the Lord." Hollie claimed "the Lord" led him there to kill the man. A couple of days before the murder, Hollie robbed a gas-station attendant at knife point because, according to Hollie, the two men had argued about religion. Shortly after the murder, Hollie turned himself in and confessed to both the armed robbery and the capital murder. The trial judge appointed an attorney to represent Hollie, and he filed a motion for a mental evaluation. A state doctor evaluated Hollie, but before a competency hearing was held, Hollie pleaded guilty to both crimes. The trial judge accepted the guilty pleas without any adjudication on Hollie’s mental status. At sentencing, Hollie put on no mitigating evidence, and he specifically instructed his attorney to put on no defense. The only thing before the jury from the defense was Hollie’s own statement to the jury, which was just one sentence. "I ask that you let the Lord deal with me and sentence me to death." The jury indeed found him guilty and sentenced him to death. Hollie filed no appeal or any motions for post-conviction relief. The matter came before the Mississippi Supreme Court on mandatory review of Hollie's death sentence. Finding that the trial court erred in ordering a mental evaluation but failing to hold a hearing on Hollie’s competency, the Court vacated Hollie’s guilty pleas, convictions, and his sentences, and remanded this case for a competency determination. View "Hollie v. Mississippi" on Justia Law

After a new trial was ordered, Brian Holliman was retried for the murder of his wife. The jury found Holliman guilty of first-degree murder, and the trial court sentenced him to life in the custody of the Mississippi Department of Corrections. He appealed, arguing: (1) the evidence of deliberate design was insufficient to support the verdict; (2) the jury instructions were improper; (3) the trial court erroneously admitted hearsay statements made by the victim; (4) the trial court erroneously denied a motion to suppress his two written statements; and (5) the trial court erred by denying his motion to quash the indictment. Finding no error, the Supreme Court affirmed. View "Holliman v. Mississippi" on Justia Law

Michael Gardner was tried and convicted of possession of more than thirty grams but less than one kilogram of marijuana, with intent to distribute. The trial judge sentenced him to ten years, day for day, as an enhanced habitual offender. Gardner appealed, arguing that “a penalty for [his] convicted offense no longer appeared” in the relevant drug statutes when he was sentenced. After review, the Supreme Court disagreed and affirmed the judgment of the Circuit Court. View "Gardner v. Mississippi" on Justia Law

Reginald Jackson was convicted of armed robbery and sentenced to thirty years with five years suspended. On appeal, Jackson argued that the prosecutors’ misconduct during opening statements and closing argument "so infected the trial with unfairness" that his right to due process was violated. Jackson additionally argues that the State failed in its burden to prove the knife used in the robbery was a deadly weapon. After review of the trial court record, the Mississippi Supreme Court found that the prosecution’s repeated misstatements of evidence and improper arguments, in the absence of an objection, did not rise to the level of reversible error in this case. Furthermore, the Court found no merit to Jackson’s contention that the State failed in its burden to prove the knife was a deadly weapon. Accordingly, the Court affirmed Jackson's conviction and sentence. View "Jackson v. Mississippi" on Justia Law

After failing to stop at a checkpoint in Jefferson Davis County, John Cole attempted to evade law-enforcement officers before subsequently crashing into a trailer. Cole ran on foot into the nearby woods and was shortly detained. A search of the area produced $6,000 in cash, which the Mississippi Bureau of Narcotics (MBN) claimed was found in close proximity to controlled substances. The MBN sought forfeiture of the property, and Anthony Brown filed a petition to contest. Brown contended that he was an innocent owner of the cash and that forfeiture was therefore improper. Finding that Brown's claim failed by default for lack of proof of an ownership interest in the property, the Supreme Court affirmed forfeiture of the money. View "Six Thousand Dollars ($6,000) v. Mississippi Ex Rel. Mississippi Bureau of Narcotics" on Justia Law

Charles Ray Crawford appealed his 1993 conviction for rape. He raised a number of issues on appeal. The record was unclear as to what caused a delay in this case being heard on appeal. For that reason, the Mississippi Supreme Court decided to set aside the procedural bar in this matter and consider the merits of Crawford's claimed errors. Having carefully reviewed this record, the Court found no merit to any of Crawford's alleged errors and affirmed his conviction. View "Crawford v. Mississippi" on Justia Law

Tommie Claiborne was convicted of murder and sentenced to life. According to three eyewitnesses, Claiborne chased his wife around a car, grabbed her, and shot her three times the day before their scheduled divorce hearing. Claiborne's appellate counsel filed a "Lindsey" brief. But Claiborne filed a pro se brief asserting ineffective assistance of counsel. He also argued the State violated discovery rules, the eyewitnesses at trial contradicted their statements to police, and that he was denied a speedy trial. Upon review, the Supreme Court concluded Claiborne's appeal indeed presented no arguable issues. The Court dismissed the other issues Claiborne raised in his pro se brief without prejudice so that he might raise them in any post-conviction proceedings. The Court therefore affirmed Claiborne's conviction and sentence. View "Claiborne v. Mississippi" on Justia Law

Scott Bates was convicted of simple assault of a law-enforcement officer. He appealed the conviction, claiming he could not be guilty of the enhanced crime of simple assault on a law-enforcement officer because the officer he assaulted, Deputy Sheriff James Cox, was working off-duty as a private security guard. The Mississippi Court of Appeals affirmed Bates’ conviction. Bates thereafter petitioned for writ of certiorari, which was granted on the question of whether there was sufficient evidence to support a finding that Deputy Cox was acting within the scope of his duty, office, or employment as a law-enforcement officer. Finding that State presented sufficient evidence to support the jury’s finding, the Supreme Court affirmed. View "Bates v. Mississippi" on Justia Law

Jairus Collins was convicted of murdering Ebony Jenkins. He appealed, raised several points of error, but the Court of Appeals affirmed. Finding that Collins’s statement to police should have been suppressed and that one of the State’s witnesses should have been qualified as an expert prior to giving opinion testimony regarding the locations of Collins’s and Jenkins’s cellular phones, the Supreme Court reversed the judgments of the Court of Appeals and the trial court, and remanded the case for further proceedings. View "Collins v. Mississippi" on Justia Law

In 2010, a George County sheriff's deputy attempted to pull over a Chevrolet pickup truck. The truck did not stop, and a high-speed chase ensued. In the truck were defendant Christopher Baxter and Brandy Williams. In an effort to apprehend the two, the Sheriff's Department set up a roadblock. The truck still would not stop, and Sheriff Garry Welford was run over and killed. Baxter and Williams were charged with capital murder and tried separately. Baxter was convicted and sentenced to life in prison without the possibility of parole. He appealed, and the Court of Appeals affirmed his conviction. Baxter raised several issues on appeal to the Supreme Court, namely: (1) that the jury was improperly instructed on accomplice responsibility; and (2) that the circuit court erred in admitting Baxter's involuntary, unreliable and coerced "confession." Finding no reversible error in the circuit court's judgment, the Supreme Court affirmed. View "Baxter v. Mississippi" on Justia Law