Justia Mississippi Supreme Court Opinion Summaries

Justin Anderson was convicted by jury of first degree murder for the killing of Michael McLendon. He was sentenced to life in prison. On appeal, Anderson challenged his conviction and sentence, arguing: (1) the trial court erred by denying his heat of passion jury instruction; (2) the trial court plainly erred by allowing his confession to be presented to the jury; and (3) that the verdict was against the overwhelming weight of the evidence. Finding no error, the Mississippi Supreme Court affirmed Anderson’s conviction and sentence. View "Anderson v. Mississippi" on Justia Law

Elmer Norwood appealed his conviction for aggravated domestic violence, claiming that his trial counsel was constitutionally ineffective for failing to introduce evidence that would have impacted his accuser’s credibility. Finding no merit to Norwood’s ineffective-assistance-of-counsel claim, the Mississippi Supreme Court affirmed Norwood’s conviction. View "Norwood v. Mississippi" on Justia Law

On April 7, 2020, Matthew Wallace was hired by the Centreville Police Department, located in the Town of Centreville, Mississippi. In 2021, Wallace was dispatched with a Town of Centreville certified police officer, to a scene involving multiple juveniles riding all-terrain vehicles in the town limits. An altercation occurred; at some point during the altercation, Wallace went to the patrol unit to retrieve the police-issued pepper spray. Upon returning to the scene, Wallace released the pepper spray. Sometime following the incident, one of the juveniles and his mother filed charges against Wallace for simple assault on a minor. The issue presented for the Mississippi Supreme Court's review centered around a probable cause hearing pursuant to Mississippi Code Section 99-3-28. Before the hearing, the State petitioned the circuit court to determine whether Wallace was entitled to a probable cause hearing, alleging Wallace was not a sworn law enforcement officer. At the hearing, the circuit determined that Wallace was not a sworn law enforcement officer and, therefore, was not entitled to a probable cause hearing. Wallace moved the circuit court for a probable cause hearing for the same underlying incident. The circuit court denied the motion, finding, again, that Wallace was not a sworn law enforcement officer and, therefore, was not entitled to a probable cause hearing under Section 99-3-28. Wallace appealed. The Supreme Court held that a law enforcement officer who is not certified pursuant to Mississippi Code Section 45-6-11(3)(a) is not entitled to a probable cause hearing under Mississippi Code Section 99-3-28(1)(a)(i). Further, the Court held Wallace was not entitled to a probable cause hearing under Section 99-3-28(1)(a)(i) because he was not a law enforcement officer as defined by Mississippi Code Section 45-6-3(c). View "Wallace v. Mississippi" on Justia Law

Troy Eaton was convicted by jury of second-degree murder for the shooting and death of Josh Smith and of aggravated assault for the shooting of Ricky Dale Vick. On appeal, Eaton challenged the admission of a glass pipe into evidence, the sufficiency of the evidence, and the weight and credibility of the evidence. Finding no error, the Mississippi Supreme Court affirmed the convictions and sentences. View "Eaton v. Mississippi" on Justia Law

Samuel Anderson was convicted by jury of the murder of his grandmother, Evelyn Davenport. On appeal, Anderson argued the trial court erred by refusing an accident-or-misfortune jury instruction and by admitting evidence of Anderson’s other bad acts. Finding Anderson's claims lacked merit, the Mississippi Supreme Court affirmed. View "Anderson v. Mississippi" on Justia Law

David Sills was convicted of possession of methamphetamine greater than two grams but less than ten grams in violation of Mississippi Code Section 41-29-139 (Rev. 2018). Sills appealed, arguing: (1) the jury’s verdict was against the overwhelming weight of the evidence; (2) the State failed to meet its burden of proof regarding constructive possession; and (3) the trial court erred by denying Sills’ motion to suppress illegally obtained evidence. Finding no merit to either claim, the Mississippi Supreme Court affirmed Sills’ conviction. View "Sills v. Mississippi" on Justia Law

Wade Willard, Sr. was convicted by jury for possession of methamphetamine, for which he was sentenced to twelve years as a habitual offender. On direct appeal to the Mississippi Supreme Court, Willard argued the trial court erred in striking two potential jurors for cause and erred in limiting his cross examination of the arresting error. After review of the trial court record, the Supreme Court found no reversible error and affirmed Willard’s conviction and sentence. View "Willard v. Mississippi" on Justia Law

Lorenzo Manuel was convicted by jury of second-degree murder and aggravated assault. At sentencing, the trial judge found that Manuel was a habitual offender and sentenced him to forty years for second-degree murder and twenty years for aggravated assault. The judge ordered that these sentences were to run consecutively and without reduction, suspension, or possibility of parole. Manuel appealed, and the Mississippi Court of Appeal affirmed the trial court's judgment. The Mississippi Supreme Court granted Manuel’s petition for writ of certiorari to review the trial judge’s imposition of a habitual offender sentence. The Supreme Court found that the trial judge lacked sufficient evidence to sentence Manuel as a habitual offender. Additionally, the Court found that the Court of Appeals erred when it allowed the State to supplement the record with copies of the indictments for Manuel’s prior offenses. Therefore, the Court vacated Manuel’s habitual offender sentence and remanedd the case to the trial court to resentence Manuel as a nonhabitual offender. View "Manuel v. Mississippi" on Justia Law

Alberto Garcia confessed to raping and murdering five-year-old JT. He pled guilty to capital murder and waived jury sentencing. After a hearing, the trial judge sentenced Garcia to death. He appealed his sentence, and the Mississippi Supreme Court affirmed. He sought post-conviction relief from his sentence or leave to proceed in the trial court for further post-conviction proceedings. In his motion, Garcia argues his trial counsel provided constitutionally ineffective assistance. While he asserted his attorneys were deficient for three reasons, his primary claim was that counsel failed to pursue and present at the sentencing hearing evidence of fetal alcohol syndrome disorder (FASD) as a mitigating factor. After review, the Supreme Court found Garcia failed to present a substantial showing that his trial attorneys were deficient in investigating potential FASD, let alone that any prejudice resulted. "[T]here is no reasonable probability that FASD evidence would have caused the sentencing judge to find that the mitigators outweighed the aggravators, which included the heinous nature of Garcia’s crime." The Court likewise found Garcia failed to show deficiency and resulting prejudice on his other two ineffective-assistance-of-counsel claims. Therefore, his motion was denied. View "Garcia v. Mississippi" on Justia Law

Marlon Howell was indicted by grand jury for the sale of a controlled substance in 1998. The indictment charged Howell with one count of the sale of 6.8 grams of marijuana, a Schedule 1 controlled substance. At the time of Howell’s charging, Mississippi Code Section 41-29-139(b)(3) (Rev. 1993) provided for a penalty of three years’ imprisonment and/or a fine up to $3,000 for the sale of one ounce or less of marijuana. In 1999, the State and Howell agreed to reduce Howell’s felony charge from the sale of a controlled substance to possession of a controlled substance. The parties presented an agreed order reducing Howell’s felony charge to possession. On the same day, Howell pled guilty to the reduced felony charge of possession of a controlled substance. Howell was thereafter sentenced to three years in custody of the Mississippi Department of Corrections with one year of house arrest and the remaining two years of post-release supervision in addition to $200 in restitution. In 2016, Howell moved to vacate the sentence for felony possession, arguing the sentence he received was illegal. The trial court treated Howell’s motion as a post-conviction relief petition and found that Howell lacked standing under Mississippi’s post-conviction relief statutes because Howell had already completed his sentence for drug possession. Howell then appealed. The Mississippi Supreme Court reversed and remanded, finding that “[o]n the narrow question presented, interpreting Mississippi Code Section 99-39-5(1), we hold that Howell has standing.” On remand, the trial court found that Howell’s post-conviction relief petition was time-barred. The court also found that the original sentence was not illegal and that Howell had benefitted from a more lenient sentence for the crime with which he was originally charged. Howell appealed the trial court’s denial of his motion for post-conviction relief. Finding no reversible error in the trial court's judgment, the Supreme Court affirmed. View "Howell v. Mississippi" on Justia Law