Justia Mississippi Supreme Court Opinion Summaries

Brandon Spiers was arrested on charges of burglary of a dwelling and attempted sexual battery. He was convicted on both charges. Spiers was sentenced to serve twenty-five years under the supervision of the Mississippi Department of Corrections (MDOC) for the burglary-of-a-dwelling conviction, and he was sentenced to thirty years under the supervision of MDOC for the attempted sexual battery conviction. The sentence for attempted sexual battery was ordered to run consecutively with the burglary-of-a-dwelling sentence. Spiers appealed arguing: (1) the trial court erred by granting a jury instruction requiring Spiers to prove the affirmative defense of consent by clear and convincing evidence; and (2) the State engaged in prosecutorial misconduct during its closing argument. Upon review of the record, the Mississippi Supreme Court affirmed Spiers’s convictions. View "Spiers v. Mississippi" on Justia Law

Jerry Beale was convicted of two counts of attempted murder and was sentenced to serve thirty-five years in the custody of the Mississippi Department of Corrections. The Court of Appeals found no reversible error. The Mississippi Supreme Court granted certiorari because one of the issues raised by Beale had never been addressed by the Court: that his indictment was defective because it lacked the essential element of an overt act. Beale further argued that the jury instructions constructively amended the indictment. The Supreme Court found that Beale’s indictment correctly stated the necessary elements of attempted murder. Furthermore, the Court found that jury instructions 8 and 9 did not constructively amend the indictment. View "Beale v. Mississippi" on Justia Law

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