Justia Mississippi Supreme Court Opinion Summaries

Concerned with the sufficiency of process in multiple paternity and child-support cases, Chancellor D. Neil Harris conducted a hearing in which he found an individual process-server, Guy Jernigan; a notary, Thomas McDonald; and an owner of a process service company, Edwin Chesire (collectively, "Defendants"), to be in civil contempt of court for causing the filing of false proof-of-service affidavits. Ten days after the initial contempt hearing, the chancellor held a "sentencing hearing" in which he made all the Defendants jointly and severally liable for $88,500 in sanctions, required Jernigan and McDonald to issue written apologizes to the other chancellors in the Sixteenth Chancery Court District, and banned them from ever again serving process or notarizing documents for the Sixteenth Chancery Court District. The chancellor further ordered all the Defendants to be incarcerated every weekend until the reimbursements were received and the apologizes were made. The Supreme Court subsequently found that the judgments were for constructive criminal contempt, as opposed to civil contempt. Thus, Chancellor Harris was bound by the additional due-process safeguards which govern constructive criminal contempt proceedings and erred by neither recusing himself from the proceedings nor notifying the Defendants of the specific criminal charges against them. The Court vacated the contempt judgments on these procedural grounds and remanded the case to the Jackson County Chancery Court for further proceedings. View "In Re: Thomas Corey McDonald and Edwin Cheshire" on Justia Law

Robert Rowland appealed a circuit court judgment that denied his motion for post-conviction collateral relief. Rowland claimed that he was placed in double jeopardy when he was convicted on two counts of armed robbery and two counts of capital murder for killing while engaged in the commission of those same two armed robberies. Upon review, the Supreme Court agreed, and vacated Rowland's separate armed-robbery convictions and sentences and reversed the circuit court denying Rowland's petition for post-conviction relief. View "Rowland v. Mississippi" on Justia Law

Robert Lee Jenkins was convicted for possession of a controlled substance. He was sentenced to life imprisonment under the habitual-offender statute. On appeal, 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

In the summer of 2008, Lonnie Young shot and killed his wife's lover at a family reunion. Young was convicted of murder and sentenced to life in prison. Young raised four issues on appeal. The Court of Appeals affirmed and the Supreme Court granted certiorari to consider: (1) whether the trial court should be reversed for denying Young an opportunity to impeach a witness; (2) and/or for denying Young's imperfect-self-defense jury instruction. The Court agreed with the Court of Appeals in finding that, although the trial court erred in denying Young the opportunity fully to impeach defense witness Shakitay Harris, this error was harmless. The Court found no error in the trial court's denial of Young's imperfect-self-defense jury instruction. Therefore, the Court affirmed the judgments of the Court of Appeals and Circuit Court. View "Young v. Mississippi" on Justia Law

Defendant James Wayland Mosley was sentenced to a total of 126 years in the custody of the Mississippi Department of Corrections (MDOC) after a jury convicted him on one count of selling cocaine, one count of selling methamphetamine, and one count of selling marijuana (less than thirty grams). Mosley appealed the sentence to the Supreme Court claiming that the trial court’s sentencing order is disproportionate to the crimes he committed and violated his constitutional protections against cruel and unusual punishment. Because the Court found that the trial court did not abuse its discretion, Mosley’s sentences were neither disproportionate to the crimes he committed nor outside the limits prescribed by statute, the Court affirmed the trial court’s sentencing order. View "Mosley v. Mississippi" on Justia Law

Glenn Wane Hawkins was convicted by a jury of murdering his girlfriend, Rita Fair, and given a mandatory life sentence. Hawkins timely filed a direct appeal to the Supreme Court, claiming that the evidence was insufficient to support a conviction. Hawkins also raised issues regarding a jury instruction which outlined the distinctions between depraved heart murder and culpable negligence manslaughter. Finding no error, the Supreme Court affirmed his conviction and sentence. View "Hawkins v. Mississippi" on Justia Law

Mississippi Department of Human Services ("DHS") retained a law firm for a large number of paternity and child-support cases. The law firm contracted process-service companies to serve defendants in the DHS cases. Individual process servers were instructed to serve process on a defendant, complete a proof-of-service affidavit, and send it to the owners of the process-service companies. In four cases, the DHS defendants testified that they had not been served personally. The chancellor then issued show-cause orders for a hearing and issued subpoenas instanter, requiring the process servers (the appellants in this case) to appear and demonstrate why they should not be held in contempt for failing to serve process as set forth in their proof-of-service affidavits and for signing the affidavits outside the notary's presence. Appellants directly appealed criminal contempt orders for failing to serve or improperly serving process on defendants in paternity and child-support proceedings and for notarizing proof-of-service affidavits outside the presence of the affiants. The chancellor initially found Appellants in civil contempt and ordered a sentencing hearing. However, after conducting that hearing, he proceeded to hold all in direct criminal contempt. Appellants submitted, and the State conceded, that the alleged conduct was not direct criminal contempt, but constructive criminal contempt. Upon review, the Supreme Court concluded that because the conduct was not civil contempt or direct criminal contempt, the chancellor should have recused himself from the proceedings. The Appellants were entitled to the due-process safeguards required for constructive criminal contempt proceedings. Accordingly, the Court reversed the contempt judgments and remanded the cases for entry of an order of recusal, and for further proceedings. View "Corr v. Mississippi" on Justia Law

Cecil Ben was convicted of rape and sentenced to life imprisonment by circuit court. The Court of Appeals affirmed his conviction and sentence. In his petition for writ of certiorari, Ben argued: (1) that his constitutional right to a speedy trial was violated; (2) that Otis Mingo's testimony was inadmissible due to a discovery violation by the State; (3) that the admission of Maurice Hines's hearsay testimony was not harmless error; (4) that the admission of Nurse Sharon Hockett's statement concerning Monica's veracity was improper; and (5) that the verdict was contrary to the weight and the sufficiency of the evidence. Finding no error, the Supreme Court affirmed Ben's conviction and sentence. View "Ben v. Mississippi" on Justia Law

Henry Taylor and Eddie Ray Jones were tried jointly for aggravated assault and possession of a firearm by a felon. Taylor was found guilty on both charges, and Jones was acquitted on the latter charge but convicted on the former charge. Jones appealed his aggravated-assault conviction, and the Court of Appeals affirmed Jones's conviction and sentence. After the Court of Appeals denied his motion for rehearing, Jones filed a petition for writ of certiorari which the Supreme Court granted to consider, inter alia, Jones's claims of inconsistent verdicts and erroneous jury instructions. The Court held that Jones's claims of error were without merit; thus the Court affirmed the judgments of the Court of Appeals and the circuit court. View "Jones v. Mississippi" on Justia Law

Three death-row inmates, Robert Simon, Rodney Gray, and Benny Stevens, along with the groups, Mississippians Educating for Smart Justice and Mississippi CURE, Inc. (collectively, the petitioners) filed a complaint in circuit court, seeking a writ of mandamus, injunctive relief, and/or a declaratory judgment against the Mississippi Department of Corrections (MDOC). The complaint alleged that the MDOC's newly-adopted execution protocol was invalid pursuant to Mississippi Administrative Procedures Law (MAPL) because the MDOC had adopted a new rule with regard to the MDOC's lethal injection protocol without first meeting the notice-and-comment requirements set forth by the MAPL. The circuit court denied relief, finding that the MDOC's lethal injection protocol was exempted from the MAPL because the MAPL specifically excludes matters "directly related to inmates." Accordingly, the Supreme Court found that the MDOC execution protocol was a "regulation or statement" related only to inmates of the MDOC and is therefore exempt from the provisions of the MAPL. The protocol is an internal policy concerning lethal injections and the manner in which executions are carried out and is therefore not subject to the notice and comment requirements of the MAPL. Thus, the Court affirmed the circuit court's judgment. View "Mississippians Educating for Smart Justice, Inc. v. Miss. Dept. of Corrections" on Justia Law