Justia Mississippi Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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At Anthony Lafayette's murder trial, when the jury informed the trial judge that it could not reach a unanimous verdict, the judge responded to the jurors that if they could not reach a verdict, he would call a new jury that would be "reasonable and fair" and that he hoped not to put the "County and State to the expense" if he could get around it. Lafayette moved for a mistrial, but the judge denied the motion, and Lafayette was convicted of manslaughter. On review, the Supreme Court found that the trial judge's instruction was inappropriate, and it "require[d]" that the Court reverse and remand the case for a new trial. View "Lafayette v. Mississippi" on Justia Law

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David Anthony Jackson appeals his house-burglary conviction and twenty-five-year penitentiary sentence. The home of former United States Senator Trent Lott was burglarized in 2009 for which Jackson was indicted by a grand jury. On October 29, 2010, Jackson filed a Motion for Judgment Notwithstanding the Verdict, Or In The Alternative, For A New Trial. The circuit court denied this motion. Jackson filed this appeal, raising three assignments of error: (1) that the evidence was insufficient to sustain his conviction, specifically that the State failed to establish Jackson’s intent to commit the crime of larceny once inside the house; (2) that the trial court erred in refusing to give Jackson’s proffered jury instruction for the lesser-included offense of trespass; and (3) that the trial court erred in denying Jackson’s Motion for a Directed Verdict and his Motion for Judgment Notwithstanding the Verdict, or in the Alternative, for a New Trial. Finding no error, the Supreme Court affirmed Jackson's conviction and sentence. View "Jackson v. Mississippi" on Justia Law

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In 2005, Eddie Mitchell shot and killed Cliff Patterson while both were working as mechanics at Anglin Tire in Jackson, Mississippi. Mitchell claimed that he killed Patterson in self-defense. A jury found Mitchell guilty of murder, and as a result, the trial court sentenced Mitchell to life in prison. At issue on appeal was whether the trial court properly instructed the jury on self-defense and manslaughter; whether the trial court erred in admitting evidence of a past physical altercation between Mitchell and a former coworker; whether prosecutorial misconduct existed in cross-examination and closing arguments; and whether trial counsel was ineffective. Upon review, the Supreme Court concluded that the trial court properly instructed the jury on self-defense and manslaughter, and did not err in allowing the prosecution to question Mitchell about a past physical altercation with a former coworker. The Court could not find evidence of prosecutorial misconduct, nor could it substantiate Mitchell's claim of ineffective assistance of counsel. Accordingly, the Court affirmed Mitchell's conviction and sentence. View "Mitchell v. Mississippi" on Justia Law

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Defendant Justin Springer was convicted of capital murder by a jury in the Circuit Court of Lee County on May 6, 2011. The underlying felony was burglary. For this conviction, he was sentenced to life in the custody of the Mississippi Department of Corrections, without the possibility of parole. After the trial court's denial of his post-trial motions, Defendant appealed to the Supreme Court, alleging that the verdict was contrary to the overwhelming weight of the evidence. Finding that the verdict against him was not contrary to the overwhelming weight of the evidence, the Court affirmed his conviction and sentence. View "Springer v. Mississippi" on Justia Law

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Following a jury trial in the Circuit Court of Tippah County, Mississippi, fifty-fouryear-old Roger Green was convicted of two counts of sexual battery and two counts of touching a child for lustful purposes involving D.W., Green's ten-year-old stepdaughter. Following denial of Green's "Motion for Judgment Notwithstanding the Verdict or in the Alternative For a New Trial," Green filed this appeal. Before the Supreme Court, Green argued that the circuit court abused its discretion in admitting evidence of other sexual offenses through the testimony of four other minor girls whom he allegedly inappropriately touched. He also challenged the sufficiency of the evidence to support the charges against him. Finding no error from trial nor an abuse of discretion by the trial court, the Supreme Court affirmed Green's conviction. View "Green v. Mississippi" on Justia Law

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Defendant Shawn States was found guilty of capital murder for killing two people while committing armed robbery. Defendant raised three arguments on appeal: (1) the prosecution discriminated based on race and gender in its peremptory strikes; (2) the trial court failed to grant circumstantial-evidence instructions; and (3) the trial court improperly granted the prosecution a "flight" instruction. Because the Supreme Court found no reversible error, Defendant's conviction was affirmed. View "States v. Mississippi" on Justia Law

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In early 2011, Defendant Jonathan Havard was convicted by a jury in George County Circuit Court for the deliberate-design murder of his girlfriend, Joy Hodges. He was sentenced to life imprisonment. On appeal, Defendant requested his conviction and sentence be overturned, or, in the alternative, reversed and remanded for a new trial. Appellate counsel filed a "Lindsey"1 brief certifying to the Supreme Court there were no appealable issues in the record. Believing otherwise, Defendant filed a brief pro se assigning error to both the trial court and defense counsel. The alleged errors include violations of his Sixth Amendment right to a speedy trial, his Fifth Amendment right to refrain from testifying, inadequate jury instructions, ineffective assistance of counsel, and failure to grant a change in venue. Upon review, the Supreme Court disagreed and found the allegations of error to be lacking in merit. Therefore, the Court denied Defendant's requested relief and affirmed the decision of the trial court. View "Havard v. Mississippi" on Justia Law

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In 1992, Defendant Jeffrey Davis was convicted of murder and sentenced to death. After the Supreme Court affirmed his conviction and sentence on direct appeal, he filed a petition for post-conviction relief, claiming, among other things, that he was denied effective assistance of counsel at the sentencing phase of his trial. Based on the evidence produced by Defendant's new counsel (evidence that was available to but never discovered or produced by his trial counsel), the Court reversed the trial court's denial of post-conviction relief and remanded the case for a new sentencing trial. View "Davis v. Mississippi" on Justia Law

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The Supreme Court granted certiorari in this case to address whether in a driving-under-the-influence trial, the admission of intoxilyzer calibration records, in lieu of the live testimony of the person who calibrated the Clause contained in the Sixth Amendment to the United States Constitution. Finding no constitutional violation, the Court affirmed the judgments of the Court of Appeals and the Madison County Circuit Court: "[the are nontestimonial in nature. Therefore, [Defendant's] Confrontation-Clause rights were not violated." View "Matthies v. Mississippi" on Justia Law

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In 2006, Defendant Ladennis Graham pled guilty to simple possession of approximately twelve grams of cocaine. The circuit court sentenced Defendant to serve sixteen years in the Mississippi Department of Corrections (MDOC) with fifteen years to be suspended upon the successful completion of twelve months of house arrest, four years of supervised post-release supervision and completion of a community service program. While Defendant was on house arrest, MDOC determined he violated the conditions of his suspended sentence when he was arrested at his brother's house during the execution of a search warrant, which turned up a number of guns and narcotics. Defendant was required to serve the remainder of his sixteen-year sentence as an inmate. Defendant then filed a motion for post-conviction relief (PCR) which was dismissed for lack of subject matter jurisdiction. On appeal, the Court of Appeals found that Defendant's sentence was illegally vague and indeterminate, and remanded the case for revocation of Defendant's sentence if the circuit court or State chose to initiate such a proceeding. Upon review, the Supreme Court concluded the Court of Appeals was correct in reversing the circuit court’s ruling that it did not have proper jurisdiction to hear Defendant's motion for post-conviction collateral relief. However, it was improper for the Court of Appeals to rule on the merits of Defendant's motion without the circuit court doing so first, as the circuit-court had exclusive, original jurisdiction. The judgment of the Court of Appeals was vacated; the circuit court judgment was reversed, and the case was remanded to the circuit court for further proceedings. View "Graham v. Mississippi" on Justia Law