Justia Mississippi Supreme Court Opinion Summaries

Elizabeth Swain and Mona Cates lived together from 2000 until 2006. After they severed their relationship, Swain filed an action seeking the repayment of funds she first had invested in a property in Washington State, which were then used to purchase a residence in Mississippi. The chancellor rejected Swain's claim of a constructive trust or a resulting trust. The chancellor found that Cates had been unjustly enriched by Swain's contributions and awarded Swain a judgment in that amount. The Court of Appeals affirmed the chancellor's rejection of the trust claim but reversed the decision of the chancellor, which was based on unjust enrichment. The Court of Appeals held that, because “cohabitation alone cannot form the basis of an equitable remedy between non-married cohabitants,” the remedy of unjust enrichment was outside the bounds of the chancery court's equitable powers. Upon review, the Supreme Court found that the chancellor was empowered to award relief on the basis of unjust enrichment. The Court affirmed the judgment of the Court of Appeals to the extent that it affirmed the chancellor's rejection of Swain's claim of a constructive trust or a resulting trust. The Court reversed the judgment of the Court of Appeals with regard to the unjust-enrichment award. Because the chancellor made a mathematical error in the calculation of the unjust-enrichment award, the Court vacated the chancellor's judgment in part, and remanded the case to the chancery court for entry of judgment in the correct amount. View "Cates v. Swain" on Justia Law

Kenton and Katherine McNeese executed a consent agreement to an irreconcilable differences divorce, and the chancellor granted the divorce on that ground. Kenton filed a motion to reconsider, which was denied. Kenton appealed the denial of his post-trial motion to reconsider as well as the grant of divorce based on irreconcilable differences. Finding no error, the Supreme Court affirmed the chancery court. View "McNeese v. McNeese" on Justia Law

Martin Vance filed a medical-malpractice/wrongful-death action on behalf of Mamie Vance Hemphill, alleging that Dr. Charles H. Laney was negligent in his treatment of the decedent, Hemphill. Vance initially sued other medical providers, but all but Dr. Laney were dismissed. Trial was held; Dr. Laney was the sole defendant. The jury returned a verdict of $1,000,000 to Vance. In response, Dr. Laney filed this appeal, presenting three issues to the Supreme Court: (1) whether the trial court erred in remitting plaintiff's economic damage award to $103,688 when the substantial weight of the evidence proved that the award should have been zero; (2) whether the trial court erred in its jury instructions; and, (3) whether plaintiff's counsel made inappropriate comments, and, when taken with the erroneous jury instructions, should have warranted Dr. Laney a new trial. Because the trial judge committed reversible error in instructing the jury that they could consider the "value of life" of the deceased in awarding damages, and because counsel for Vance made improper and prejudicial comments to the jury during closing arguments, the Supreme Court reversed and remanded for a new trial. View "Laney v. Vance" on Justia Law

Blayde Grayson was indicted for capital murder while in the commission of burglary with the intent to steal personal property. A jury found him guilty of capital murder and, in a separate sentencing proceeding, sentenced him to death. The Supreme Court affirmed Grayson's conviction and death sentence. In early 2003, Grayson filed his first petition seeking post-conviction collateral relief (PCR). The Supreme Court denied relief. Grayson then filed his "Motion for Leave to File Successor Petition for Post-Conviction Relief" and "Motion for Access." Upon review, the Supreme Court concluded that PCR petitioners who have been sentenced to death do have a right to the effective assistance of PCR counsel. Grayson's counsel in his first PCR proceedings before the Supreme Court rendered deficient performance. However, Grayson failed to show that this deficient performance prejudiced him. Therefore, Grayson's claim that he received ineffective assistance of PCR counsel was deemed without merit. Furthermore, Grayson failed to show that his claims met any exceptions to the procedural bars, and his "Motion for Leave to File Successor Petition for Post-Conviction Relief" was dismissed as procedurally barred. Grayson was hereby granted leave to proceed in the circuit court with a motion for access. "As a matter of due process, Grayson should be allowed access to his experts, subject to the rules and regulations of the Mississippi Department of Corrections (MDOC). Because MDOC's rules and regulations presently require a court order, MDOC should be noticed with the request for access and afforded an opportunity to show cause why its present policies do not violate petitioner's due-process rights." View "Grayson v. Mississippi" on Justia Law

The issue before the Supreme Court in this case concerned premises liability in the context of a wrongful death action. The Court of Appeals affirmed the trial court's holding that the deceased was an invitee at the time of his death and that the plaintiff breached no duty to the deceased under the standard applied to those classified as invitees while on the property of another. Upon review, the Supreme Court agreed the grant of summary judgment was appropriate but disagreed with the trial court and the Court of Appeals as to the reason. The Court found that the injured party was not an invitee at the time of the incident, but a trespasser. Because both the Court of Appeals and the trial court incorrectly classified the decedent as an invitee, the Court affirmed only the result. View "Handy v. Nejam" on Justia Law

Travis Keithley was convicted for aggravated assault. On appeal, he argued that it was plain error to admit into evidence the "statements" of two anonymous people, that the verdict was not supported by the evidence, and that he received ineffective assistance of counsel. Finding no reversible error, the Supreme Court affirmed Keithley's conviction and sentence, and dismissed his ineffective-assistance-of-counsel claims without prejudice. View "Keithley v. Mississippi" on Justia Law

Twonia Renee Williams was convicted for the murder of Katrina Sergeant. She was sentenced to life imprisonment in the custody of the Mississippi Department of Corrections (MADOC). On appeal, Williams contended that jury instructions S-2A, S-4, and/or S-6 were given in error. Upon review, the Supreme Court concluded that the circuit court erred in granting instruction S-4, and such error could not be considered harmless in this case. Therefore, Williams's conviction and sentence were reversed and the case remanded for a new trial. View "Williams v. Mississippi" on Justia Law

The Supreme Court reversed the conviction and sentence in the first trial in this case in 2009, and remanded the case to the trial court, finding that the defendant, Tomarcus Fulks, had been entitled to a continuance based on the State's untimely disclosure of a key witness. In 2011, a jury reconvicted Fulks of armed robbery and acquitted him of aggravated assault. He received a sentence of thirty-five years in the custody of the Mississippi Department of Corrections (MDOC). On appeal, Fulks argued: (1) the trial court erred in allowing the State to introduce Fulks's prior testimony from his first trial; (2) the trial court erred in denying Fulks's motion for recusal; (3) the trial court erred in allowing the prosecutor to inform the jury that coindictee Joshua Glenn had entered a plea of guilty to a charge of aiding and abetting after the fact; and (4) the trial court erred when it allowed prior testimony of State's witness Sherry Franks, who was found to be "unavailable" for trial, into evidence. Finding no error, the Supreme Court affirmed. View "Fulks v. Mississippi" on Justia Law

Shirley LaFontaine appealed an order which the Supreme Court found to be a nonfinal judgment. Because her appeal was not properly before the Court, it dismissed her appeal and remanded the case to the Circuit Court. View "LaFontaine v. Holliday" on Justia Law

David Parvin appealed his murder conviction, characterizing his arguments as "a 'Weathersby' case with a 'Daubert' twist." Parvin maintained that his wife's death was caused by accident, and the State's principal evidence refuting his defense at trial consisted of expert testimony, accompanied by a computer-generated reconstruction of the scene of her demise. The State argued that the experts' opinions about the physical evidence proved the victim was intentionally killed. Although the Supreme Court found no merit in Parvin's Weathersby claim, the Court agreed that certain expert testimony and the visual depiction of that testimony should not have been presented to the jury. Because this evidence severely prejudiced Parvin's defense, the Court reversed the conviction and remand the case to the Circuit Court for a new trial. View "Parvin v. Mississippi" on Justia Law