Justia Mississippi Supreme Court Opinion Summaries

A caller informed Claiborne County Sheriff's deputies that Wendell Barnes was in Port Gibson driving a car with Texas plates. Officers knew Barnes had three warrants against him. They happened upon a vehicle matching the caller's description and initiated an investigatory stop. A deputy searched and arrested the driver, Defendant Terrance Eaddy, for possession of cocaine and weapons. Defendant moved to suppress evidence of the drugs and gun discovered in the search. At the suppression hearing, on cross-examination of the arresting deputy, defense counsel pointed out that the deputy's report contained a different version of events that took place at the time of Defendant's arrest than his testimony. In ruling on Defendant's motion, the court recognized the deputy's report differed from his testimony, but that "an arrest report does not represent the officer's entire description of the arrest." Accordingly, the court denied Defendant's motion to suppress. A jury convicted Defendant of the charges against him. On appeal to the Supreme Court, Defendant argued that the trial court should have suppressed the evidence presented at trial. Upon review, the Supreme Court found that the deputies did not have reasonable grounds to justify the investigatory stop and subsequent search and seizure of evidence from Defendant. Accordingly, the Court vacated Defendant's conviction.

Defendant Curtis Gause was indicted on capital murder charges in addition to burglary, and aggravated assault. A jury found him guilty of manslaughter and burglary, and not guilty of assault. The circuit court sentenced Defendant to twenty years for manslaughter and twenty-five years for burglary, with sentences to run consecutively in the state Department of Corrections. Defendant appealed, arguing multiple errors at trial. Principal among them, Defendant contended the trial court erred when it allowed the jury to consider a verdict on burglary. Upon careful consideration of the trial court's record and the applicable legal authority, the Supreme Court found that the trial court erred by granting the burglary jury instruction. The Court found that burglary was not a "lesser-included" offense to capital murder, and only Defendant could have asked for the "lesser-included" instruction. The Court affirmed Defendant's conviction on manslaughter, but reversed his conviction on burglary. The Court remanded the case for further proceedings.

A grand jury indicted Vanessa Decker under the state Vulnerable Adults Act of 1986 for using her elderly mother's money "without her consent." But at trial, the evidence established that Ms. Decker did obtain her mother's consent to use the money. The State requested a jury instruction that allowed the jury to find Ms. Decker guilty, even if her mother had given consent. The judge granted the State's request. Subsequently, Ms. Decker was convicted by the court and sentenced to four months' imprisonment. Additionally, Ms. Decker was sentenced to pay restitution, fines and court costs. Ms. Decker appealed her conviction. Upon review of the trial record, the Supreme Court found that the trial judge gave a jury instruction that materially changed the charge made by the grand jury in the indictment. Accordingly, the Court reversed the trial court's conviction and sentence. The Court remanded the case for further proceedings.

Defendant Gregory Redmond appealed his conviction of statutory rape. He was sentenced to life. On appeal to the Supreme Court, Defendant argued that the trial court made errors by admitting some and excluding other testimony that was ultimately prejudicial to his case. Upon consideration of the record and the applicable legal authority, the Supreme Court found no error by the trial court. The Court affirmed Defendant's conviction and sentence.

Defendant Dennis Taylor appealed his conviction for conspiracy and robbery. He was sentenced to fifteen years. On appeal to the Supreme Court, Defendant argued that the verdicts against him at trial were against the weight and sufficiency of the evidence. Upon consideration of the arguments and the applicable legal authority, the Supreme Court found that the evidence was sufficient to support the jury's verdicts, and that the verdicts were not against the overwhelming weight of the evidence. The Court affirmed Defendant's conviction and sentence.

A grand jury indicted Defendant Harold Hargett for selling marijuana and hydrocodone. A jury found Defendant guilty, and he was sentenced as a habitual offender to six years for the marijuana charge, and sixty years for the hydrocodone charge. The appellate court affirmed Defendant's sentence. Defendant appealed to the Supreme Court by arguing that the trial court erred by admitting testimony that referenced certain "prior bad acts" that should have been excluded. Before trial began, defense counsel argued in a motion to exclude evidence that Defendant's prior convictions would be too prejudicial. The trial court granted the motion. Despite the ruling, the State continually elicited inadmissible testimony that referenced the prior convictions. The Supreme Court reversed the decisions of the trial and appellate courts and remanded the case for a new trial. The Court found that the testimony that referenced Defendant's prior bad acts should have been excluded.

In September, 2007, a grand jury returned a two-count indictment against Defendant Albert Joiner. One count charged Defendant with âfelony flight,â and the second count charged Defendant with being a felon in possession of a deadly weapon. The indictment did not charge Defendant as being a âhabitual offender.â In a separate case, Defendant had a pending indictment for armed robbery as a habitual offender. Defendant and the State reached a plea agreement: the State would dismiss the possession charge and reduce the armed-robbery charge if Defendant would plead guilty to felony flight and robbery as a âlesser habitual offender.â Defendant accepted the deal, pled guilty, and was sentenced to a total of nineteen years as a habitual offender. Defendant moved for post-conviction relief, arguing that the trial court erred by charging him as a habitual offender when the grand juryâs indictment made no mention of it. The trial judge summarily denied his petition, and Defendant appealed. The Supreme Court found that because of Defendantâs âknowing an voluntary guilty plea,â Defendant waived his right to contest any deficiency in the indictment. The Court affirmed the lower courtsâ decisions.

In September, 2008, after a jury trial, Appellant Timmy Harden was convicted of the statutory rape of his stepdaughter. In December, Appellant was sentenced to twenty yearsâ imprisonment, to be followed by ten years of post-release supervision, with five years reporting. Appellant appealed his sentence, arguing among other things, that the trial court should have granted him a continuance in order that he could obtain a mental evaluation to decide whether he was fit to stand trial. Furthermore, Appellant argued that the evidence presented at trial was insufficient to convict him. The Supreme Court was unconvinced that any additional evidence provided at the trial would have reasonably raised doubt as to the Appellantâs competence to stand trial. In addition, the Court found that the evidence did not âpreponderate so heavily against the verdict as to cause an unconscionable injustice.â The Court affirmed Appellantâs conviction and sentence.