Justia Mississippi Supreme Court Opinion Summaries

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

Defendant Gary Glidden was convicted of one count of possession of a controlled substance. The circuit court sentenced him to serve a term of four years in the custody of the Mississippi Department of Corrections. The court also sentenced Defendant to serve his imprisonment as an habitual offender. After entering an order denying Defendant's motion for a judgment notwithstanding the verdict, or in the alternative, for a new trial, Defendant perfected his appeal to the Supreme Court. Finding that no reversible error occurred at trial, the Supreme Court affirmed the judgment of the Court of Appeals, which affirmed the judgment of conviction and sentence of the circuit court. View "Glidden v. Mississippi" on Justia Law

Defendant Leo Wales was tried in absentia for two counts of armed robbery and two counts of aggravated assault. A jury found Defendant guilty on all counts, and the Circuit Court of Hinds County sentenced Defendant to twenty years, and forty years for each count of armed robbery and assault, each sentence to run concurrently in the Mississippi Department of Corrections. Defendant's consecutive and concurrent sentences required him to serve a total of eighty years. On appeal, Defendant argued that (1) the trial court erred in trying him in absentia; (2) the evidence was insufficient to support his conviction in Count I, aggravated assault or, alternatively, the verdict of guilty in Count I was against the overwhelming weight of the evidence; and (3) the trial court erred by denying his proffered jury instruction on the specific intent required for armed robbery. The Supreme Court affirmed Defendant's convictions and sentence, because it found substantial evidence supported the trial court’s finding that he had waived his right to be present at trial, because the evidence was sufficient to support the verdict of guilty in Count I, and that verdict was not against the overwhelming weight of the evidence, and because the jury instructions, taken as a whole, fully and fairly informed the jury of each element of the crime of armed robbery. View "Wales v. Mississippi" on Justia Law

Jules Corbin, Tammy Louis, and James Henry, Jr. were involved in an automobile wreck that left Louis dead and Henry severely injured. Corbin was indicted for capital murder, aggravated assault, and felony fleeing the scene of an accident. However, he was convicted by a jury on the lesser-included offense of murder, as well as aggravated assault and felony fleeing the scene. Corbin was sentenced to life imprisonment for murder, ten years for aggravated assault, and three years for felony fleeing. Corbin appealed, and claimed among other things, that his Sixth-Amendment right to confrontation was violated. Upon review of the trial court record, the Supreme Court agreed that Corbin's constitutional rights were violated, and that the error was not harmless as to the charges of murder and aggravated assault, but that it was harmless as to the charge of felony fleeing the scene of an accident. Thus, the Court reversed and remanded part, and affirmed part of the trial court's decision. View "Corbin v. Mississippi" on Justia Law

Defendant Amanda Goforth, a former high-school teacher, was indicted on five counts of sexual battery involving one of her former students. She was convicted on two counts and acquitted on the remaining three. Because the Supreme Court in its review found that Defendant was not afforded a constitutionally adequate opportunity to confront one of the witnesses against her, the Court reversed the trial court's decision. Further, the Court found that Defendant's conviction and sentence must be reversed and rendered: "[a]ny subsequent reprosecution would subject Goforth to the dangers of double jeopardy due to the multiple, identically worded counts in her indictment and the jury’s split verdict." View "Goforth v. Mississippi" on Justia Law

Defendant Michael Richardson was convicted by a jury capital murder and of being a convicted felon in possession of a firearm. The State sought the death penalty at the sentencing phase, but the jury returned a verdict of life imprisonment without the possibility of parole for the capital murder charge. The trial judge sentenced Defendant to serve a term of life without parole for the capital-murder conviction, and to serve a term of ten years imprisonment for the felony-possession-of-firearm conviction. These two sentences were ordered to be served consecutively, all in the custody of the Mississippi Department of Corrections. After the trial court denied Defendant's motion for a new trial, or in the alternative, motion for judgment notwithstanding the verdicts, Defendant appealed, alleging errors at the trial court level. Finding Defendant's assignments of error to be without merit, the Supreme Court affirmed the trial court's judgment. View "Richardson v. Mississippi" on Justia Law

Defendant Roger Thorson was indicted in 1987 and charged with the capital murder of Gloria McKinney, his ex-girlfriend, during the commission of a kidnapping. On Thorson’s direct appeal of his capital-murder conviction and sentence of death, the Supreme Court affirmed the trial court on all issues except a 'Batson' issue, and the case was remanded to the trial court to conduct a Batson hearing. On remand, the trial court found no Batson violation, holding that Defendant was not entitled to a new trial. On appeal, the Supreme Court found that the trial court had committed reversible error in allowing the State to peremptorily strike a member of the jury venire based solely on her religious affiliation, in violation of Article 3, Section 18 of the Mississippi Constitution and Mississippi Code Section 13-5-2. The case was reversed and remanded for a new trial. After another jury trial, Defendant was again convicted for the crime of capital murder and sentenced to death by lethal injection, and on appeal, the Supreme Court affirmed both the conviction and sentence. The United States Supreme Court denied Defendant's petition for writ of certiorari. Defendant subsequently filed a Petition for Post-Conviction Relief with this Court, seeking an 'Atkins' hearing pursuant to 'Atkins v. Virginia.' Once all briefs had been submitted, the court entered an eight-page order thoroughly discussing the issue before him and finding that Defendant was not mentally retarded under 'Atkins.' Upon entry of this order denying his petition for post-conviction relief under Atkins, Defendant appealed again to the Supreme Court. Upon review, the Supreme Court found that the trial court did not abuse its discretion by finding that Defendant was not mentally retarded. View "Thorson v. Mississippi" on Justia Law