Justia Mississippi Supreme Court Opinion Summaries

In this case, the Supreme Court of Mississippi reviewed the convictions and death sentences of Willie Cory Godbolt, who was found guilty of several counts of murder, kidnapping, attempted murder, and armed robbery. The Court addressed numerous issues raised by Godbolt, including whether the trial court erred by denying his motions to sever the charges, transfer the trial venue, limit voir dire, suppress certain evidence, and exclude victim impact testimony. Godbolt also claimed that his counsel provided ineffective assistance and that his death sentences were unconstitutional.The Court rejected all of Godbolt's claims, finding no error in the trial court's decisions or in the handling of his case. It affirmed Godbolt's convictions and sentences, holding among other things that the evidence supported the jury's findings of guilt and the imposition of the death penalty, the trial court properly admitted certain evidence, and Godbolt's counsel did not provide ineffective assistance. The Court also found that Godbolt's death sentences did not violate the constitution. View "Godbolt v. State of Mississippi" on Justia Law

The case at hand involves an appeal from Lady B. Garth against the Monroe County Circuit Court's dismissal of her appeal of a criminal misdemeanor conviction. The Supreme Court of Mississippi was tasked with determining whether the lower court erred in this dismissal.The pivotal issue revolved around the procedural aspects of perfecting an appeal from a justice court to a circuit court. According to Mississippi law, this requires a simultaneous filing of a written notice of appeal, a cost bond, and an appearance bond within 30 days of judgment. In this case, Garth failed to comply with these requirements. While she faxed a written notice of appeal on the 30th day following the original judgment, the cost bond and appearance bond were not submitted until six days later.The court concluded that Mississippi law does not permit the filing of the required bonds past the 30-day appeal time, and as such, the Monroe County Circuit Court committed no error in dismissing Garth's appeal. Therefore, the Supreme Court of Mississippi affirmed the lower court's decision.It should be noted that while Garth raised additional issues concerning the merits of the underlying justice-court judgment and alleged ineffective assistance of counsel, these were deemed outside the scope of the present appeal or more appropriately raised in post-conviction-relief petitions, and were thus not considered by the court in this decision. View "Garth v. State of Mississippi" on Justia Law

Percy Harris, a staff sergeant in the Mississippi Army National Guard, was convicted of first-degree murder of his wife, Shauna. Harris testified that during an argument, Shauna shot herself while he attempted to prevent her from doing so. However, Harris's stepson, M.K., testified that he heard his mother pleading with Harris not to shoot her. The prosecution pointed to several inconsistencies in Harris's account, such as the nature of Shauna's injuries and the fact that she was shot three times when Harris claimed to only hear two shots.On appeal, Harris argued that the prosecutor committed misconduct during her closing arguments, including making "send-a-message" and "golden-rule" arguments, commenting on his right to trial, and inflaming the jury's emotions. The Supreme Court of Mississippi disagreed, finding that the prosecutor's statements were not inflammatory and were within permissible bounds. The prosecutor's comments on Harris's credibility and demeanor were allowed because Harris chose to testify, hence putting his credibility and demeanor at issue. The Court affirmed Harris's conviction and life sentence. View "Harris v. State of Mississippi" on Justia Law

Jeremy Underwood was convicted of manslaughter in Mississippi for the stabbing death of Marcus Steele. Underwood appealed, claiming that the evidence was insufficient to prove beyond a reasonable doubt that he did not act in self-defense under the Castle Doctrine (which allows a person to use deadly force in certain situations when threatened in their own home), that the verdict was against the overwhelming weight of the evidence under the Castle Doctrine, and that the prosecution engaged in misconduct during opening and closing arguments. The Supreme Court of Mississippi affirmed the conviction, finding that the Castle Doctrine did not apply to this case and that the evidence was sufficient to support a manslaughter conviction. The court also found that the prosecutor's comments during opening and closing arguments did not constitute misconduct. Underwood had sold cocaine to Steele and Broach and claimed that Steele and Broach had forcibly entered his home multiple times before the stabbing occurred during an argument on Underwood's porch. However, the court found that the evidence did not support Underwood's claims that he was in imminent danger when he stabbed Steele. View "Underwood v. State of Mississippi" on Justia Law

In this case, the Supreme Court of Mississippi heard an appeal by Christopher Stewart who was convicted on two counts of sexual battery against his two preteen nieces. Stewart argued that he was entitled to a new trial because he was not physically present at a pretrial tender-years hearing due to COVID-19 restrictions and also claimed that the evidence presented was insufficient. The court affirmed both convictions and sentences. It held that Stewart's virtual attendance at the hearing due to the COVID-19 pandemic did not constitute reversible error as he was able to cross-examine the witnesses at the trial where he was physically present. The court referred to a similar case (Kentucky v. Stincer) where the Supreme Court found no Confrontation Clause or due-process violation for a defendant's exclusion from a pretrial hearing. As for the sufficiency of the evidence, the court rejected Stewart's claim that the State had to prove all three methods of penetration (vaginal, anal, and oral) as charged in the indictment. The court found that there was evidence of all three types of penetration and, in any case, the State only needed to prove one form of penetration to establish the offense of sexual battery. View "Christopher Stewart v. State of Mississippi" on Justia Law

The Supreme Court of Mississippi reviewed the case of Jameco Davis and Jacqlaurence Jackson, who were convicted of two counts of first-degree murder. Both men contested their convictions and sentences. They argued that the trial court made errors in adding a firearm enhancement to their sentences, in failing to follow proper procedures to review a Batson challenge (a challenge against racial bias in jury selection), and that the verdict was against the overwhelming weight of the evidence. Jackson additionally argued that the evidence was insufficient to support the verdict, that the trial court erred in denying his motion to sever and have separate trials, and that the cumulative effect of these errors denied him a fair trial.The Supreme Court found that the firearm enhancement portions of the sentences should be vacated, as the sentence for first-degree murder, life in prison, was greater than the five years provided for in the firearm enhancement statute. The court disagreed with the remaining arguments, stating that the trial court's failure to follow proper procedures for a Batson challenge was not clearly erroneous and did not prejudice the defendants, and there was no evidence to support the claim that the trial court's cumulative errors denied Jackson a fair trial. The court also found that the evidence was enough to support the verdict. The court thus vacated the firearm enhancement portions of the sentences, and affirmed the remaining convictions and sentences. View "Davis v. State of Mississippi" on Justia Law

In this criminal case heard by the Supreme Court of Mississippi, Willie Douglas was convicted and sentenced to life imprisonment as a habitual offender for two counts of sale of less than two grams of cocaine. The cocaine was sold to a confidential informant, Ronald Keen, during two controlled purchases that were orchestrated and monitored by law enforcement officers from the Batesville Police Department. The substances bought during these controlled purchases were tested and confirmed to be cocaine by the Mississippi Forensics Laboratory.On appeal, Douglas raised multiple issues, including an illegal sentence, improper indictment, denial of the right to self-representation, bias of the trial judge, and credibility of witnesses, among others. The Supreme Court of Mississippi found all his claims to be without merit. It held that there was no violation of Douglas's constitutional rights and the evidence presented at trial was sufficient to uphold the jury's verdict. The court affirmed the conviction and life sentence. View "Douglas v. State of Mississippi" on Justia Law

Timothy Robert Ronk, who was convicted of armed robbery and capital murder and sentenced to death, sought post-conviction relief for a second time. He claimed his post-conviction counsel was ineffective. The State of Mississippi, in response, requested an overruling of Grayson v. State, which held that ineffective-assistance-of-post-conviction-counsel claims are an exception to the bars in the Mississippi Uniform Post-Conviction Collateral Relief Act (UPCCRA). The Supreme Court of Mississippi agreed with the State, citing a recent decision (Howell v. State) which invalidated all cases in which Mississippi courts had applied a "judicially crafted fundamental-rights exception" to the UPCCRA’s bars. Therefore, the court partially overruled Grayson and denied Ronk's request for post-conviction relief. The court determined that Ronk's claims, including that his trial counsel failed to investigate his case thoroughly and that the State suppressed evidence, lacked arguable basis, were insufficient to overcome the statutory bars, and did not meet the "newly-discovered-evidence" exception. View "Ronk v. State of Mississippi" on Justia Law

In the case at hand, the Supreme Court of Mississippi dealt with an appeal by George Hawkins who was convicted for sexual battery of a minor under Mississippi Code Section 97-3-95(2). This law requires the State to prove that the defendant was in a position of trust or authority over the minor when the crime was committed. Hawkins' appeal was based on the argument that the State failed to present sufficient evidence of him being in such a position over the victim, as he had no legal authority over her.In 2014, Hawkins began dating Tonya Ingram and gradually became a part of her and her children’s lives, to the point where they even considered themselves to be common-law married. In the spring of 2015, Tonya and her children moved into Hawkins's home "as a family". Hawkins and Tonya filed their taxes jointly, claimed Tonya’s children as dependents, and contributed equally to the family’s finances. The victim, Jane, one of Tonya's children, trusted Hawkins, which ended when he sexually assaulted her one night.The court found that while Hawkins did not possess any legal authority over Jane, a reasonable jury could have concluded that he was in a position of trust or authority over her based on the totality of the circumstances and their relationship. The court held that the list of individuals who are typically in positions of authority provided in Section 97-3-95(2) serves only as examples, and does not limit this to persons in positions of legal authority over the child. Therefore, the court affirmed Hawkins' conviction. View "Hawkins v. State of Mississippi" on Justia Law

In this criminal case, the Supreme Court of Mississippi upheld the conviction of the defendant, Adam Mills, for first-degree murder. The case stemmed from Mills brutally killing his girlfriend while allegedly under the influence of drugs. Mills appealed his conviction, arguing that he could not be convicted of first-degree murder because the evidence did not support a finding that he had the requisite mental capacity to form a premeditated intent to kill. Mills also contended that the trial court erred by admitting photographs and body camera footage from the crime scene.The Supreme Court held that the trial court did not abuse its discretion by admitting the photographs and body camera footage. It reasoned that the materials served a useful evidentiary purpose by providing the jury with visual evidence of the crime scene and the victim’s injuries, which could aid in determining Mills's intent. Regarding the defendant's argument about his mental capacity, the Court ruled that voluntary intoxication is not a defense to a specific-intent crime such as first-degree murder. The Court held that the extent and nature of the victim's injuries, inflicted by Mills, were indicative of a deliberate design to kill.Therefore, the Court affirmed Mills's conviction and life sentence for first-degree murder. View "Mills v. State of Mississippi" on Justia Law