Justia Mississippi Supreme Court Opinion Summaries

Allen Rogers, Jr. was convicted by a jury of two counts of child sex abuse and was sentenced to a total of thirty-three years' imprisonment. In Count One, Rogers was convicted of sexual battery against eight-year-old "Benjamin Hicks". In Count Two, Rogers was convicted of fondling "William Hicks," Benjamin's eleven-year-old brother. Rogers appealed, arguing that the trial court erred by overruling his hearsay objection to statements made by Benjamin to a forensic psychologist. He also argued that the State failed to prove that Count Two occurred in Scott County, as alleged in the indictment. Finding error on both counts, the Supreme Court reversed Rogers's convictions and sentences and remanded the case for a new trial. View "Rogers, Jr. v. Mississippi" on Justia Law

Marshall Keith Watkins was convicted of possession with intent to distribute five separate controlled substances and simple possession of one controlled substance. Watkins appealed his conviction, arguing the trial court erred by: 1) refusing to dismiss Counts Two through Six of his indictment based on double jeopardy; 2) granting several jury instructions submitted by the State on the morning of closing arguments; 3) permitting a jury instruction based upon constructive possession; and 4) excluding evidence related to the disposition of the two other individuals indicted with Watkins. Watkins also argued that the cumulative effect of the alleged errors deprived him of a fair trial, and asks the Supreme Court to reverse his conviction. Upon review, the Court found all of Watkins's assigned errors are without merit and affirmed his conviction and sentence. View "Watkins v. Mississippi" on Justia Law

In this case, the trial judge erroneously denied Defendant Merlin Hardison's peremptory strike during voir dire, holding that the juror's previous service on a jury in a criminal case was not a race-neutral reason for the strike: the juror had expressed regret that the jury was unable to reach a verdict. Defendant's jury ultimately convicted him, and this appeal followed. Defendant raised nine alleged issues of error at the trial court. Upon review, the Supreme Court found that the trial judge's denial of Defnedant's peremptory strike to be dispositive. Accordingly, the Court affirmed Defendant's conviction. View "Hardison v. Mississippi" on Justia Law

Defendant Matthew Miller was tried and convicted of aggravated assault and forcible rape of his girlfriend's minor daughter. The Supreme Court assigned the case to the Court of Appeals who affirmed Defendant's convictions and sentences. Defendant appealed to the Supreme Court, which found reversible error in the trial judge's failing to recuse himself after having served as the county prosecutor in an earlier youth-court shelter hearing regarding the minor victim's custody as a result of Defendant's actions at issue in this case. Accordingly, the Court reversed the appellate court's and the trial court's judgments and remanded the case for a new trial. View "Miller v. Mississippi" on Justia Law

A Pike County jury convicted James Richard Conners Jr. of two counts of murder and two counts of possession of a firearm by a felon. The circuit court imposed two life sentences for the murder convictions and two ten-year sentences for the possession-of-a-firearm-by-a-felon convictions, with all sentences to run consecutively. Conners appealed, arguing that the admission of two forensic reports at his trial violated his right of confrontation under the Sixth Amendment to the United States Constitution and constituted plain error. He also argued that he received ineffective assistance of counsel due to counsel's failure to make a Confrontation Clause objection to the admission of the forensic reports, and due to counsel's failure to object to gruesome photographs and evidence of Conners's past criminal activity and gang affiliation. Upon review, the Supreme Court found that the trial court erred by admitting the forensic test reports without live testimony from the analysts who performed the tests, but that the error was harmless. Furthermore, the Court found that Conners did not receive ineffective assistance of counsel, because he could not show that he was prejudiced by any deficient performance by counsel. Therefore, the Court affirmed his convictions and sentences. View "Conners v. Mississippi" on Justia Law

Defendant Jeffrey Yeatman filed a motion for post-conviction relief in circuit court. The motion was denied, and Defendant appealed. The Court of Appeals affirmed. Defendant raised three issues on appeal to the Supreme Court: (1) whether Defendant's indictment was properly amended; (2) whether the Court of Appeals erred when it failed to address Defendant's argument that he was illegally sentenced as a habitual offender because it was not stated in his criminal information; and (3) whether Defendant's sentence was illegal because his fine exceeded the amount prescribed by statute. Upon review, the Supreme Court affirmed in part, reversed in part: the Court affirmed the amendment to the indictment, reversed the trial court's denial of Defendant's petition for post-conviction relief regarding his habitual-offender-status issue, and vacated Defendant's fine. The case was remanded to the circuit court for further proceedings. View "Yeatman v. Mississippi" on Justia Law

Defendant Darrin Wilson appealed his conviction on rape, burglary extortion and two counts of kidnapping. On appeal, Defendant challenged the sufficiency of the evidence presented against him at trial, in addition to alleging procedural errors by the trial court. Upon review of the record, the Supreme Court found all of Defendant's arguments lacked merit, and affirmed the trial court's judgment. View "Wilson v. Mississippi" on Justia Law

Defendant Ted Stone was convicted of the aggravated assault of Carolyn Stone for which he was sentenced to twenty years' incarceration and a $4,000 fine. He challenged the sufficiency of the evidence presented against him at trial. Finding no error, the Supreme Court affirmed Defendant's conviction and sentence. View "Stone v. Mississippi" on Justia Law

Defendant Rene Levario appealed the circuit court's denial of his motion to dismiss an indictment against him for felony Driving Under the Influence (DUI) Causing Death. In 2008, Defendant was involved in an automobile accident that resulted in the death of Gary Coulliette. At the scene, Defendant received five traffic tickets, one of them for DUI. Defendant posted a $25,000 bond for felony DUI Causing Death; he pled not guilty in justice court. His case was continued to October, 2008. Defendant again appeared, the charges against him were reduced to a misdemeanor, and that he pled guilty to the reduced charge. Defendant was convicted and ordered to pay a $300 fine and to attend Mississippi Alcohol Safety Education Program classes. In 2009, the State filed a "Motion to Set Aside Criminal Judgment" in justice court, arguing that the justice court had no jurisdiction to accept Defendant's plea on a charge of DUI Causing Death. After conducting a hearing on the issue, the justice court issued an order setting aside the conviction, found that Defendant had pled guilty to felony DUI Causing Death and that the felony charge had not been reduced to a misdemeanor. On October 13, 2009, the Jackson County Grand Jury returned an indictment charging Defendant with felony DUI Causing Death for the 2008 incident. On April 29, 2010, Defendant filed a Motion to Dismiss claiming double jeopardy. The circuit court overruled the motion, and Defendant appealed that decision. Upon review, the Supreme Court concluded that double jeopardy did not prohibit the State from indicting and prosecuting Defendant for felony DUI Causing Death in circuit court because the justice court did not have jurisdiction to convict him of the felony. Further, the Court concluded that the State did not violate Defendant's due-process rights in seeking to set aside his conviction in justice court and in prosecuting him in circuit court. Accordingly, the Court affirmed Defendant's conviction and sentence. View "Levario v. Mississippi" on Justia Law

A Madison County jury convicted Carla Hughes of two counts of capital murder. The jury declined to impose the death penalty, and the Circuit Court of Madison County imposed two sentences of life imprisonment without the possibility of parole, with both sentences to run concurrently. Hughes raised six issues on appeal: (1) whether the jury committed misconduct by submitting a note to the judge during deliberations asking whether the State could have called Hughes to the stand; (2) whether the verdicts were against the overwhelming weight of the evidence; (3) whether the trial court erred during jury selection when it denied one of Hughes's peremptory challenges; (4) whether the trial court erred in overruling Hughes's motion for a directed verdict; (5) whether the trial court erred by denying the motion to suppress the evidence found in Hughes's house; and (6) whether the trial court erred in admitting DNA evidence from a pair of shoes. Finding no error, the Supreme Court affirmed the circuit court's judgment. View "Hughes v. Mississippi" on Justia Law