Justia Mississippi Supreme Court Opinion Summaries

Tevin James Benjamin was found guilty of capital murder and sentenced to life without the possibility of parole. Benjamin was convicted for his alleged role in a failed carjacking that ended when an accomplice fatally wounded one of the victims. Benjamin appealed, arguing that his statement to police was taken in violation of his Miranda rights. Agreeing, the Supreme Court reversed Benjamin's conviction and sentence and remanded the case for a new trial. View " Benjamin v. Mississippi" on Justia Law

Dwayne Boyd was convicted of the sale of marijuana, greater than thirty grams but less than one kilogram, within 1,500 feet of a school or within 1,000 feet of the real property of a school. He was sentenced, as a subsequent drug offender, to 120 years in the custody of the Mississippi Department of Corrections (MDOC), with sixty years to serve and five years of supervised post-release supervision. The Court of Appeals affirmed his conviction and sentence. Upon review of Boyd's arguments on appeal, the Supreme Court concluded that the trial court did not abuse its discretion in denying Boyd's motion for continuance to secure new counsel on the day of trial. But the Court did find that Boyd did not receive timely notice that the State would seek a post-conviction amendment to the indictment and such action constituted unfair surprise. Therefore, the Court affirmed Boyd's conviction, but vacated his sentence and remanded for resentencing. View "Boyd v. Mississippi" on Justia Law

In a conviction for driving under the influence first offense, speeding, and littering, the State lost key evidence prior to the defendant's de novo trial in county court, while it was under a court order to preserve the evidence. The State's actions violated the defendant's due process right to present a complete defense. Furthermore, the county court improperly admitted proof of the radar device's accuracy under the business records hearsay exception. However, there was sufficient evidence to support the defendant's speeding conviction in the officer's testimony regarding the defendant's speed. The Supreme Court reversed the DUI conviction, but affirmed the speeding conviction, because it is supported by sufficient evidence. The Court found defendant did not adequately contest the littering conviction; thus the Court affirmed that conviction. View "Freeman v. Mississippi" on Justia Law

In 2011, Verina Childs was convicted of murdering her husband, Douglas Childs following a four-day jury trial. She was sentenced to life imprisonment in the custody of the Mississippi Department of Corrections (MDOC). After her conviction, Childs filed a motion for a new trial, which was denied. On appeal, Childs argued: (1) the State violated Childs' due-process rights by destroying evidence in violation of state law; (2) Childs was denied her fundamental right to alternative theories of defense; and (3) the State failed to prove deliberate-design murder. Because the Supreme Court found that the trial court did not err in its judgment of conviction, the Court affirmed on all three issues. View "Childs v. Mississippi" on Justia Law

After a jury trial, Randy Pauley was convicted of malicious mischief and sentenced to five years in the custody of the Mississippi Department of Corrections (MDOC) and to pay a fine, restitution, and court costs. He appealed, arguing that: (1) the trial court erred in sustaining the State's hearsay objection; (2) the trial court's denial of a continuance constituted an abuse of discretion, or, alternatively, he received ineffective assistance of counsel; (3) the trial court erred in sustaining the State's relevance objections; (4) the trial court erred in sustaining the State's objection to his redirect examination of Alicia Littlefield; (5) the indictment was fatally defective; and (6) he was entitled to a jury instruction on insanity. Finding no error, the Supreme Court affirmed. View "Pauley v. Mississippi" on Justia Law

David McLymont was convicted of capital murder and conspiracy to commit robbery. He filed a motion for judgment notwithstanding the verdict, or in the alternative, for a new trial, which the trial court denied. McLymont appealed the trial court's denial to the Supreme Court claiming his conviction was contrary to the overwhelming weight of the evidence. McLymont contended the jury relied on the testimony of a biased witness and a tape recording obtained by that witness to reach its verdict. Upon review, the Supreme Court concluded that contention was meritless. The State presented evidence against McLymont in addition to the witness and the tape recording in question. Accordingly, the trial court did not err when it denied McLymont's post-trial motion. View "McLymont v. Mississippi" on Justia Law

Bobby Batiste was convicted of capital murder with the underlying felony of robbery for the slaying of his roommate, Andreas Galanis. After a sentencing hearing, the jury determined that Batiste should be sentenced to death. The Circuit Court denied Batiste's post-trial motions. Batiste appealed, raising fifteen assignments of error. After carefully reviewing the record and Batiste's arguments, the Supreme Court found no reversible error occurred and therefore affirmed Batiste's conviction and sentence. View "Batiste v. Mississippi" on Justia Law

Dondrego Bolton was charged with burglary of a dwelling in 2010. He was found guilty and sentenced to twenty years in prison. Bolton's indictment originally charged him with breaking and entering a dwelling with the intent to commit larceny. At trial, the jury was instructed on burglary of a dwelling and the lesser-included offense of trespassing. The jury was told that if it found that Bolton had broken and entered into the home "[w]ith the intent to commit the crime of larceny or any other crime," he was guilty of burglary. Bolton did not object to the jury instructions at the time. The Court of Appeals found these jury instructions to be sufficient. Upon review, the Supreme Court concluded that under its recent holding in "Daniels v. State," (107 So. 3d 961 (Miss. 2013)), the jury did have to find that Bolton had intended to commit larceny, since that was the intended offense specified by the grand jury. Here, however, the Court of Appeals found it sufficient that "[t]he jury found beyond a reasonable doubt that Bolton intended to commit a crime in Vance's house . . . ." Bolton argued on appeal to the Supreme Court that the jury instructions were improper because they permitted the jury to convict him of burglary if it found that he had intended to commit any crime while inside the dwelling. Because the jury was improperly instructed on the essential elements of burglary consistent with the Court's recent decision in "Daniels," the Court reversed the decisions of the Court of Appeals and the Circuit Court and remanded the case to the trial court for further proceedings. View "Bolton v. Mississippi" on Justia Law

Melvin Grayer was convicted of burglary and sentenced as a habitual offender to seven years without the possibility of parole or probation. Grayer appealed, claiming that he received ineffective assistance of counsel because his trial counsel failed to request a circumstantial-evidence jury instruction and that he was sentenced as a habitual offender without competent evidence of his prior felony convictions. Upon review, the Supreme Court affirmed Grayer's conviction and sentence of seven years, but vacated his habitual-offender sentence enhancement, because the State failed to prove Grayer was a habitual offender by competent evidence. View "Grayer v. Mississippi" on Justia Law

Blayde Grayson was indicted for capital murder while in the commission of burglary with the intent to steal personal property. A jury found him guilty of capital murder and, in a separate sentencing proceeding, sentenced him to death. The Supreme Court affirmed Grayson's conviction and death sentence. In early 2003, Grayson filed his first petition seeking post-conviction collateral relief (PCR). The Supreme Court denied relief. Grayson then filed his "Motion for Leave to File Successor Petition for Post-Conviction Relief" and "Motion for Access." Upon review, the Supreme Court concluded that PCR petitioners who have been sentenced to death do have a right to the effective assistance of PCR counsel. Grayson's counsel in his first PCR proceedings before the Supreme Court rendered deficient performance. However, Grayson failed to show that this deficient performance prejudiced him. Therefore, Grayson's claim that he received ineffective assistance of PCR counsel was deemed without merit. Furthermore, Grayson failed to show that his claims met any exceptions to the procedural bars, and his "Motion for Leave to File Successor Petition for Post-Conviction Relief" was dismissed as procedurally barred. Grayson was hereby granted leave to proceed in the circuit court with a motion for access. "As a matter of due process, Grayson should be allowed access to his experts, subject to the rules and regulations of the Mississippi Department of Corrections (MDOC). Because MDOC's rules and regulations presently require a court order, MDOC should be noticed with the request for access and afforded an opportunity to show cause why its present policies do not violate petitioner's due-process rights." View "Grayson v. Mississippi" on Justia Law