Justia Mississippi Supreme Court Opinion Summaries

Defendant Deric Bailey was convicted by a jury of deliberate-design murder for which he was sentenced to life in prison. On appeal, Defendant's conviction and sentence were reversed by the Court of Appeals and the case was remanded for a new trial. At his second trial, Defendant again was convicted of deliberate-design murder and sentenced to life in prison. The trial court denied his motion for judgment notwithstanding the verdict, or in the alternative, a new trial, and Defendant timely filed this appeal. Defendant Bailey presented five issues on appeal to the Supreme Court: (1) whether the trial court erred in denying certain jury instructions; (2) whether the trial court erred in excluding from evidence the statement Defendant gave at the time of his arrest; (3) whether the jury selection process was constitutionally infirm under "Batson"; (4) whether the trial court erred in denying Defendant's motion to dismiss for failure to grant a speedy trial; and (5) whether Bailey was deprived of his right to a fair trial, or at the very least, denied his right to a fair and impartial judge. Upon review, the Supreme Court found that Defendant's claims were without merit, and affirmed Defendant's conviction and life sentence. View "Bailey v. Mississippi" on Justia Law

Defendant Gary Lee pled guilty to accessory after the fact to armed robbery in 1982. In 2010, he filed a petition for habeas corpus (post-conviction relief under Mississippi law) at the circuit court. The court denied Defendant's petition, finding it barred by the three-year statute of limitations in Mississippi Code Section 99-39-5(2) (Supp. 2011). Because Defendant's petition fell outside the three-year statute of limitations and because the trial court may dismiss a petition when it plainly appears from the face of the motion that the movant was not entitled to any relief, the Supreme Court affirmed. View "Lee v. Mississippi" on Justia Law

A jury convicted Defendant Edna Mae Sanders of murdering her husband, and she was sentenced to life in prison. The Court of Appeals reversed her conviction and remanded for a new trial based on the trial court's error in denying a "no duty to retreat" jury instruction, and based on an error in suppressing evidence. Defendant threw a pot of hot cooking oil on her husband while he was sleeping, testifying that she threw the oil to protect herself and her children after she had been violently attacked. The State argued on appeal that the Court of Appeals erred when it (1) found that Defendant was entitled to a "no duty to retreat" instruction, because the evidence showed that she reinitiated the attack after the husband had stopped attacking her; (2) incorrectly conflated the applicable statute such that the court "created precedent" for defendants to claim entitlement to the presumption of reasonable fear, even where the person "against whom 'defensive force' was used was a resident of the dwelling"; and (3) improperly invoked plain error to review the exclusion of testimony regarding the husband's alleged sexual molestation of Defendant's daughter. Upon review, the Supreme Court agreed with the Court of Appeals' ultimate disposition, and found "no merit" in the State's claims on certiorari. View "Sanders v. Mississippi" on Justia Law

The Court of Appeals reversed Defendant David Trejo's conviction and sentence for possession of a controlled substance with intent to distribute, finding the State had violated Defendant's Fourth Amendment right against unreasonable seizure. The Court held that the arresting officer lacked probable cause or reasonable suspicion to make the traffic stop that led to the discovery of cocaine; thus, the trial court should have suppressed the cocaine as fruit of the poisonous tree. While in its review the Supreme Court agreed that the officer lacked probable cause or reasonable suspicion to stop Defendant's vehicle, the Supreme Court reviewed the case to determine whether the stop was reasonable under the "community caretaking" function in "Cady v. Dombrowski." Finding the stop unreasonable under that doctrine too, the Court affirm the Court of Appeals' reversal of Defendant's conviction and sentence. View "Trejo v. Mississippi" on Justia Law

In 2010, sixteen death-sentenced inmates, including Steve Knox (the inmates), filed a complaint in the Chancery Court. The essence of their complaint was that due to defects in both the statutory structure and the performance of the Mississippi Office of Capital Post-Conviction Counsel (MOCPCC), they were deprived of their right to obtain meaningful state post-conviction and federal habeas corpus review of their convictions and death sentences. The inmates requested injunctive relief against the State due to alleged violations of their rights to competent, appointed, post-conviction counsel. The State moved to dismiss for lack of jurisdiction. After a hearing, the chancery court found that it lacked subject matter jurisdiction over the complaint because the inmates' "attack on the death sentences and post-conviction judicial reviews of [their] convictions" was cognizable under the Uniform Post-Conviction Collateral Relief Act (UPCCRA). The chancery court dismissed the complaint. Upon review, the Supreme Court affirmed, finding the chancery court lacked jurisdiction over the inmates claims because the claims were embraced by the UPCCRA. View "Knox v. Mississippi" on Justia Law

Defendant Brian Holliman was convicted for killing his wife. He was sentenced to life in prison. Defendant appealed his conviction and sentence, arguing to the Supreme Court that the prosecutor in his case made an impermissible "golden-rule" argument to the jury and that the trial court failed to instruct the jury to disregard the argument. Upon review of the trial court record, the Supreme Court found that the prosecutor's argument was a blatant violation, and the trial court erred in overruling both objections from Defendant's counsel. The Court reversed the trial court's judgment and remanded the case for a new trial. View "Holliman v. Mississippi" on Justia Law

Defendant Alvin Johnson was convicted of possession of cocaine and sentenced to sixteen years' imprisonment with nine suspended and five years of post-release supervision and a fine. The Court of Appeals affirmed Defendant's conviction and sentence. Defendant petitioned the Supreme Court for a writ of certiorari concerning two issues: (1) whether the State presented sufficient evidence to sustain his conviction; and (2) whether the agents' search of a nearby vehicle violated Defendant's right to be free from unreasonable searches and seizures within the Fourth and Fourteenth Amendments to the United States Constitution and Sections 14 and 23 of the Mississippi Constitution. The Supreme Court granted Johnson’s certiorari petition, and found Defendant's first issue to be dispositive. The State failed to prove beyond a reasonable doubt that Johnson was in constructive possession of the cocaine found in the nearby vehicle. Therefore, the circuit court erred by denying Defendant's motion for judgment notwithstanding the verdict (JNOV). Finding that proximity alone was insufficient to show constructive possession, and that the State presented no additional incriminating circumstances, the Supreme Court reversed the Court of Appeals' judgment and that of the trial court and rendered judgment in Defendant's favor. View "Johnson v. Mississippi" on Justia Law

Defendant-Appellant David Shaffer was convicted of child exploitation for soliciting sex from a twenty-nine year old female who he thought was thirteen. He argued to the Court of Appeals that the could not be guilty of child exploitation because no actual child was involved in the sting. The Court of Appeals agreed, but reversed and remanded for Defendant to be sentenced for attempted child exploitation, a crime for which he was neither indicted nor tried. Upon review, the Supreme Court found that the actual attempt to exploit a child violated the child exploitation statute. The Court reversed the Court of Appeals and reinstated and affirmed Defendant's conviction and sentence. View "Shaffer v. Mississippi" on Justia Law

After a mistrial, Defendant Stephan Hickman was retried and found guilty of capital murder with the underlying felony of robbery. The circuit court sentenced Hickman to life without parole in the custody of the Mississippi Department of Corrections. Defendant appealed, arguing that the trial court erroneously restricted his right to cross-examine a witness in violation of his right to confrontation, and that the verdict was against the overwhelming weight of the evidence. Finding no error, the Supreme Court affirmed Defendant's conviction. View "Hickman v. Mississippi" on Justia Law

Appellant Algernon Williams was convicted of shooting into a dwelling, when ballistics testing revealed that the shots were fired from a gun he had admitted owning, and which was in his possession during the time of the shooting. He claimed he received ineffective assistance of counsel at trial for not filing any post-trial motions or by failing to adequately investigate and subpoena his only proposed witness sooner. Upon review, the issues presented to the Supreme Court on appeal were not based on facts fully apparent from the record. Therefore, the Court concluded the claims were more appropriate for post-conviction-relief petitions. Viewing Appellant's petition as one for post-conviction relief, the Court reviewed the claims in light of the applicable legal authority. The Court concluded that Appellant did not show he was denied his Sixth-Amendment right to effective assistance of counsel, nor did he make an argument challenging the weight or sufficiency of the evidence presented against him at trial: "There [was] no reason to believe the outcome of this case would have been any different had [Appellant's] attorneys filed the post-trial motions at issue." Therefore the Court dismissed both of Appellant's claims without prejudice. View "Williams v. Mississippi" on Justia Law