Justia Mississippi Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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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

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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

Posted in: Criminal Law
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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

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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

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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

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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

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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

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A jury convicted Damon Fagan of four counts of sexual battery, and the trial judge sentenced him to thirty years in prison, with ten years' post-release supervision. Fagan appealed the conviction and sentence, arguing that the State's evidence was legally insufficient and that his conviction was against the overwhelming weight of the evidence. After review of the trial court record, the Supreme Court disagreed and affirmed the trial court. View "Fagan v. Mississippi" on Justia Law

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Franklin Fitzpatrick was found guilty of the murder Sheriff’s Deputy Dewayne Crenshaw. He was sentenced to life in prison without the possibility of parole. He appealed his conviction and sentence, arguing: (1) the trial court erred in giving jury instruction that allowed for conviction without a proper showing of the requisite mental state; (2) the trial court erred when it overruled Fitzpatrick’s motion for new trial based on the weight of the evidence; and (3) the trial court erred in ruling Fitzpatrick was procedurally barred from challenging the elements jury instruction on appeal because he did not object to it at trial. Because the jury instruction was a correct statement of the law, and Fitzpatrick’s arguments were otherwise without merit, the Supreme Court affirmed Fitzpatrick’s conviction and sentence. View "Fitzpatrick v. Mississippi" on Justia Law

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The Court of Appeals affirmed Timothy Carr’s conviction and sentence and denied his motion for rehearing. Carr twice sought leave from the Supreme Court to file motions for post-conviction relief (PCR) (first in May 2008, then in September 2010). The Supreme Court denied both applications. Carr filed a third application, which a panel of the Supreme Court granted in 2013. Carr then filed his PCR motion, claiming that the habitual-offender portion of his sentence should have been vacated for two reasons: (1) because the Supreme Court’s intervening decision in "Gowdy v. Mississippi," (56 So. 3d 540 (Miss. 2010)) prohibited post-conviction indictment amendments; and (2) because the prosecution failed to reintroduce evidence of his prior convictions during the sentencing phase of his trial. Carr does not here contest the validity or admissibility of his prior convictions. Finding that Gowdy did not apply to his case, the Supreme Court affirmed the Court of Appeals. View "Carr v. Mississippi" on Justia Law