Justia Mississippi Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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Alexander Gardner sued the City of Jackson, alleging that he had suffered a broken leg when one of the City's police officers forced him to sit down while in handcuffs. The City filed for summary judgment, which was denied by the trial court. On review of the City's interlocutory appeal, the Supreme Court reversed the trial court's denial of summary judgment, finding that the officer's conduct did not rise to the level of reckless disregard for Gardner's safety and well-being. View "City of Jackson v. Gardner" on Justia Law

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Following a jury trial, Talib Hannah was convicted of possession of cocaine with intent. On appeal, he raised two issues: (1) whether the circuit court abused its discretion in denying Hannah's "Motion for the State to Disclose the Identity of Its Confidential Informant;" and (2) whether the circuit court abused its discretion in denying Hannah's motion for continuance. As Hannah's Sixth Amendment right to compulsory process to call a witness was not recognized, the Supreme Court reversed his conviction and sentence and remanded the case for a new trial. View "Hannah v. Mississippi" on Justia Law

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In 2010, Edward Daniels was indicted for burglary of a dwelling. The indictment alleged that he broke and entered a dwelling with the intent to commit grand larceny. Later, the State amended the indictment to charge Daniels as a habitual offender under Mississippi Code Section 99-19-83. The trial court granted the amendment and the case went to trial. Because Daniels did not appear for trial, the case was tried in his absence. The jury found Daniels guilty, and the court delayed sentencing until Daniels could be located. The court ultimately sentenced Daniels to life without the possibility of parole under Section 99-19-83. Daniels subsequently filed a motion for a new trial or judgment notwithstanding the verdict (JNOV), which the trial court denied. Daniels appealed his conviction. Upon review, the Supreme Court reversed the decision of the trial court denying Daniels's motion for new trial and remanded the case for further proceedings, because the jury instruction on the elements of burglary "was fatally flawed." View "Daniels v. Mississippi" on Justia Law

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In 2000, Jay McCalpin pled guilty to one count of fondling and two counts of sexual battery involving a child under the age of fourteen and was sentenced to serve a term of fifteen years in the custody of the Mississippi Department of Corrections (MDOC), with ten years of his sentence suspended, and five years of post-release supervision upon his release from incarceration. In 2005, the circuit court revoked McCalpin's post-release supervision for the first time due to his failure to reside at the residence given to his supervising officer, failure to notify his supervising officer of at least three changes of residence, and failure of a drug test for marijuana. At that time, the circuit court judge revoked McCalpin's suspended ten-year sentence, ordering McCalpin to serve three years in the custody of the MDOC with seven years to remain suspended, conditioned upon McCalpin's "good behavior and that he does not violate any laws upon his release from custody." After his second release from incarceration, McCalpin's post-release supervision was revoked for a second time. McCalpin filed a motion for post-conviction relief (PCR) which was denied. He appealed the denial of his motion for PCR; the Court of Appeals affirmed. Upon review, the Supreme Court found that McCalpin did not comply with the rules of appellate procedure in seeking rehearing before the Court of Appeals. Therefore, the Court affirmed the appellate court's dismissal of McCalpin's motion for rehearing. View "McCalpin v. Mississippi" on Justia Law

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Donald Mitchell directly appealed his conviction for possession of cocaine with the intent to distribute and his habitual-offender sentence to the Supreme Court. Finding that the trial court erred by admitting evidence of Mitchell's prior convictions for possession of marijuana and cocaine, the Court reversed Mitchell's conviction, vacated his sentence, and remanded for a new trial. View "Mitchell v. Mississippi" on Justia Law

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Dante Lamar Evans was convicted of the murder of his father and sentenced as an adult to a mandatory term of life imprisonment. Evans petitioned the Supreme Court for a writ of certiorari, raising six issues: (1) whether the trial court erroneously refused to permit the jury to consider Evans's theory of imperfect self-defense; (2) whether the trial court erred in excluding testimony concerning Darold Evans's alleged abuse of Evans and his mother; (3) whether the trial court erred in refusing funds to hire a post-traumatic stress-disorder (PTSD) expert; (4) whether the trial court improperly prohibited the jury from considering Evans's age in its deliberations; (5) whether the trial court erred in admitting Evans's statements made to security guards and law-enforcement officers; and (6) whether Evans's life sentence was unconstitutional. Upon review, the Supreme Court found find that Evans demonstrated an actual need for an expert on PTSD. Therefore, the trial court abused its discretion in denying funds to hire such an expert. The Court reversed the judgment of both the Court of Appeals and the trial court and remanded for a new trial. View "Evans v. Mississippi" on Justia Law

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Marcus O'Neal Flowers a/k/a Tupac a/k/a Marcus Flowers was convicted of murder for fatally shooting Charles Wash. He claimed on appeal that the jury's verdict was against the overwhelming weight of the evidence and asked the Supreme Court for a new trial. He believed he was entitled to such relief because there were conflicts between the State's evidence and his evidence, and the credibility of the State's main witness was called into question. The Supreme Court affirmed, finding Flowers's arguments were without merit. View "Flowers v. Mississippi" on Justia Law

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Defendant Steve Antonio Anthony was convicted in circuit court for selling cocaine. He appealed his conviction, arguing that: (1) the circuit court erred by excluding evidence on cross-examination of the prior felony charges of the State's confidential informant; (2) the circuit court erred in denying two peremptory challenges raised by the defense; and (3) the jury's verdict was against the overwhelming weight of the evidence. The Court of Appeals affirmed the conviction. Defendant raised the same issues in his appeal to the Supreme Court which found that the trial court erred by limiting the cross-examination of the confidential informant. Accordingly the Court reversed Defendant's conviction and remanded the case for a new trial. View "Anthony v. Mississippi" on Justia Law

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Robert Lee Jenkins was convicted for possession of a controlled substance. He was sentenced to life imprisonment under the habitual-offender statute. The Supreme Court granted Jenkins's petition for writ of certiorari to examine whether the trial court erred by allowing a laboratory supervisor to testify regarding the results of substance testing, where the supervisor reviewed and verified the results, but another analyst actually performed the tests. Finding no error, the Court affirmed. View "Jenkins v. Mississippi" on Justia Law

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Frederick Denell Grim was convicted by jury for the sale of cocaine. The circuit court adjudicated Grim a habitual offender and sentenced him to life imprisonment without the possibility of parole. The Court of Appeals affirmed the trial court's judgment of conviction and sentence. The Supreme Court granted Grim's petition for writ of certiorari to examine whether the trial court erred by allowing a laboratory supervisor, who neither observed nor participated in the testing of the substance, to testify in place of the analyst who had performed the testing. Finding no error, the Court affirmed. View "Grim v. Mississippi" on Justia Law