Justia Mississippi Supreme Court Opinion Summaries

Pro se prisoner Edgar Earl Patton appealed his convictions on false pretense and fraudulent use of identity. He argued: (1) the circuit court judge engaged in improper ex parte communications; (2) he was denied his Sixth-Amendment right to counsel at all critical phases; (3) the circuit court erred in denying his motion to recuse the trial judge; (4) the circuit court erred by allowing a substantive amendment to the indictment; (5) he was denied the right to compulsory service of process; (6) Patton’s Fourth-Amendment protection against unlawful search and seizure was violated; (7) the circuit court erred by violating Uniform Circuit and County Court Rule 1.11; (8) the circuit court judge’s inquiry into Patton’s educational background for purposes of determining his ability to represent himself was an improper discovery tool that benefitted the State and violated his Fifth-Amendment right against self-incrimination; (9) the circuit court erred by denying Patton’s motion for directed verdict; (10) jurisdiction was improper and venue was not established; (11) the jury was improperly instructed; and (12) the indictment was legally insufficient and defective. Finding no reversible error, the Supreme Court affirmed Patton’s convictions and sentences. View "Patton v. Mississippi" on Justia Law

Howard Goodin appealed a circuit court's denial of his application for post-conviction relief. The circuit court denied Goodin’s claims that he was mentally retarded and that he had received ineffective assistance of counsel on the issues of mental illness and competency. After review of the record and pertinent authorities, the Supreme Court found that the circuit court erred in determining that Goodin was not mentally retarded. The Court also found that Goodin failed to prove ineffective assistance of counsel regarding competency at the conviction stage. Because these issues were dispositive, the Court did not address Goodin’s claim of ineffective assistance of counsel on the issue of mental illness. The circuit court's judgment was affirmed in part and reversed in part. Goodin's death sentence was vacated and this case was remanded to the Circuit Court of Newton County for resentencing on the capital murder charge. View "Goodin v. Mississippi" on Justia Law

The issue on direct appeal to the Supreme Court in this case involved Quincy Clayton's conviction for the murder of his wife Alice. The Court found the trial court erred in depriving Clayton submission of an alternative theory of defense, when his requested jury instruction on heat-of-passion excusable homicide was refused. Accordingly, the Court reversed and remanded this case to the Jones County Circuit Court for a new trial. View "Clayton v. Mississippi" on Justia Law

A Harrison County grand jury indicted Mark Kee Brown for felony escape, and as a habitual offender under Mississippi Code Section 99-19-81. The State later moved the trial court to amend the grand jury’s indictment to charge Brown as a habitual offender under Section 99-19-83 – a statute that requires a life sentence for defendants with two previous felony convictions, one of which was a “crime of violence.” The trial judge held that a prior conviction for burglary satisfied the violent-crime requirement for habitual-offender status, even though the State had produced no evidence that the burglary involved violence. Brown appealed. Because burglary is not a crime against the person, and not, as the Court of Appeals held, a per se crime of violence, the Supreme Court reversed the lower courts and remanded this case for further proceedings. View " Brown v. Mississippi" on Justia Law

Ahmad Butler was convicted of manslaughter by a jury for which he was sentenced to twenty years in the custody of the Mississippi Department of Corrections. Butler appealed, claiming that pretrial photo lineups were overly suggestive, that identifications were unreliable, and that the trial judge erred in denying his motion for a new trial. Finding that Butler's arguments were without merit, the Supreme Court affirmed the trial court's judgment of conviction and Butler's sentence. View "Butler v. Mississippi" on Justia Law

Lessadolla Sowers was convicted in the Tunica County Circuit Court of ten counts of voter fraud as a habitual offender. Mississippi Bureau of Investigations officers determined that a significant number of absentee ballots had been mailed to a post office box held in Sowers's name. She was sentenced to five years in the custody of the Mississippi Department of Corrections for each count, with each sentence ordered to run concurrently with the others. Sowers appealed, arguing that the State presented insufficient evidence at trial to sustain the jury's verdicts of guilt on the ten counts of voter fraud and her habitual-offender status. Finding otherwise, the Supreme Court affirmed Sowers's convictions and sentence. View "Sowers v. Mississippi" on Justia Law

Johnny R. Young, Jr. was convicted in the Circuit Court of Union County on three counts of sexual battery of his minor daughter and was sentenced to three concurrent life sentences. The Supreme Court assigned Young's appeal to the Court of Appeals, which unanimously affirmed. The Court granted certiorari to consider two of Young's issues and found that: (1) the circuit court did not err by admitting evidence that Young had sexually assaulted his stepsister when she was five and he was fifteen, because the circuit court found the prior assault probative of a noncharacter issue under Mississippi Rule of Evidence 404(b); and (2) the sexual-assault nurse examiner who examined "Cindy" was amply qualified by her training and experience to testify regarding the cause of the hymenal tear or rupture that she had observed while examining Cindy. Thus, the Court affirmed the trial and appellate courts' judgments. View "Young v. Mississippi" on Justia Law

A jury found Anthony Mercie Expose guilty of having forcible sexual intercourse with Shannon M. Bessee. The Court of Appeals reversed and remanded his conviction because it found that the trial court had erred in refusing an instruction that would have informed the jury that consent is a defense to forcible sexual intercourse and that the State had the burden of proving that Bessee had not consented. Upon review, the Supreme Court found that the trial court did not err in refusing this instruction. Additionally, the Court found that the post-trial discovery of a domestic-violence conviction involving Bessee's husband did not warrant a new trial. Therefore, the Court reversed the judgment of the Court of Appeals and affirmed the verdict and sentence Circuit Court. View "Expose v. Mississippi" on Justia Law

The trial court sentenced Charles Harris as a habitual offender to the maximum twenty years for aggravated assault, and to ten years for being a convicted felon who used a firearm in the commission of a felony. But the statute that authorizes a ten-year sentence for using a firearm in the commission of a felony does not apply where a "greater minimum sentence" is available under some other provision of law. And because the minimum sentence available for Harris's habitual status exceeded ten years, the Supreme Court vacated his sentences and reversed and remanded the case to the Circuit Court for re-sentencing. View "Harris v. Mississippi" on Justia Law

Frederick Denell Grim was convicted by jury for the sale of cocaine. The circuit judge adjudicated Grim a habitual offender and sentenced him to life imprisonment without the possibility of parole. 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