Justia Mississippi Supreme Court Opinion Summaries

The issue on direct appeal to the Supreme Court in this case involved Quincy Clayton's conviction for the murder of his wife Alice. The Court found the trial court erred in depriving Clayton submission of an alternative theory of defense, when his requested jury instruction on heat-of-passion excusable homicide was refused. Accordingly, the Court reversed and remanded this case to the Jones County Circuit Court for a new trial. View "Clayton v. Mississippi" on Justia Law

A Harrison County grand jury indicted Mark Kee Brown for felony escape, and as a habitual offender under Mississippi Code Section 99-19-81. The State later moved the trial court to amend the grand jury’s indictment to charge Brown as a habitual offender under Section 99-19-83 – a statute that requires a life sentence for defendants with two previous felony convictions, one of which was a “crime of violence.” The trial judge held that a prior conviction for burglary satisfied the violent-crime requirement for habitual-offender status, even though the State had produced no evidence that the burglary involved violence. Brown appealed. Because burglary is not a crime against the person, and not, as the Court of Appeals held, a per se crime of violence, the Supreme Court reversed the lower courts and remanded this case for further proceedings. View " Brown v. Mississippi" on Justia Law

The Jackson County Court sitting as Youth Court exercised jurisdiction over two minors following allegations of abuse and neglect. The foster parents of the two minor children subsequently filed adoption proceedings in the Lincoln County Chancery Court. The Mississippi Department of Human Services ("MDHS") sought interlocutory appeal after unsuccessfully challenging the chancery court's jurisdiction to consider the adoption proceedings. Upon review, the Supreme Court found that the Chancery Court had jurisdiction over the adoption proceedings and affirmed the Chancery Court's judgment. View "Mississippi Dept. of Human Svcs. v. Watts" on Justia Law

In this interlocutory appeal, Ford Motor Company (Ford) wanted to preserve a confidential settlement agreement between it and the Estate and wrongful-death beneficiaries of Brian Cole (the Coles). The case on appeal was a separate action between the Coles, their attorneys, and among the attorneys themselves regarding expenses, a contingency-fee agreement, and a fee-sharing agreement. The chancellor denied Ford's motion and its "Notice of Intent to Seek Closure of Proceedings and Sealing of Documents." Before the Supreme Court, Ford raised three issues: (1) whether the settlement agreement was a public, judicial record or a private contract, which should be enforced; (2) whether the state's policy encouraging settlement agreements and the parties' interest in abiding by the terms of that agreement were sufficient grounds to protect the settlement from public scrutiny; and (3) whether there was any overriding public interest which would require disclosure of the terms of the settlement agreement. Upon review, the Supreme Court found that the settlement agreement was between private parties, did not involve issues of public concern, and was unnecessary to resolve the parties' disputes. Thus, the Court concluded that chancery court erred, in part, by denying Ford's motions. View "In the Matter of the Estate of Brian Cole" on Justia Law

Ahmad Butler was convicted of manslaughter by a jury for which he was sentenced to twenty years in the custody of the Mississippi Department of Corrections. Butler appealed, claiming that pretrial photo lineups were overly suggestive, that identifications were unreliable, and that the trial judge erred in denying his motion for a new trial. Finding that Butler's arguments were without merit, the Supreme Court affirmed the trial court's judgment of conviction and Butler's sentence. View "Butler v. Mississippi" on Justia Law

Michael Travis died in 1997 when a train struck his vehicle at a railroad crossing. His mother, Mary Travis, filed a wrongful-death suit against Illinois Central Railroad Company and its employees (collectively "Illinois Central") in Circuit Court. Trial was held in October 2009, and the jury assessed damages in the amount of $6.5 million. Based on the jury's allocation of fault, the trial court entered a judgment in favor of Travis in the amount of $4,875,000. Illinois Central filed this appeal. Upon review, the Supreme Court reversed and remanded the case for further proceedings, finding that the trial court erred in denying Illinois Central's motion for judgment notwithstanding the verdict, because the evidence did not support the jury’s verdict. View "Illinois Central Gulf Railroad Company v. Travis" on Justia Law

This consolidated appeal stemmed from a lawsuit in which Mark Wolgin sued various entities alleging wrongdoing surrounding his 2006 purchase of a condominium on the Gulf Coast. In case #2010-CA-00653-SCT, Wolgin appealed the Chancery Court's decision to dismiss two credit reporting agencies (Trans Union LLC and Experian Information Solutions, Inc. ("Experian")), finding that claims against them were preempted by the Fair Credit Reporting Act ("FCRA"). In case #2010-CA-01177-SCT, the broker for the sale, The Power Broker, Inc. ("Power Broker"), appealed the Chancery Court's decision to order discovery on the scope of the mandatory arbitration clause in the "Contract for the Sale and Purchase of Real Estate" instead of fully granting its "Motion to Compel Arbitration." Regarding Wolgin's appeal, the Supreme Court affirmed the trial court's order dismissing the credit reporting agencies, as Wolgin's claims are preempted by the FCRA. As to Power Broker's appeal, the Court reversed the trial court judgment ordering discovery and remanded the case with instructions to stay the proceedings and refer the matter to arbitration. View "Wolgin v. Experian Information Solutions, Inc." on Justia Law

Lessadolla Sowers was convicted in the Tunica County Circuit Court of ten counts of voter fraud as a habitual offender. Mississippi Bureau of Investigations officers determined that a significant number of absentee ballots had been mailed to a post office box held in Sowers's name. She was sentenced to five years in the custody of the Mississippi Department of Corrections for each count, with each sentence ordered to run concurrently with the others. Sowers appealed, arguing that the State presented insufficient evidence at trial to sustain the jury's verdicts of guilt on the ten counts of voter fraud and her habitual-offender status. Finding otherwise, the Supreme Court affirmed Sowers's convictions and sentence. View "Sowers v. Mississippi" on Justia Law

The two subscribing witnesses to Lela W. Holmes’s will testified that they did not know they were witnessing a will; that Lela did not request they witness a will; and that they did nothing to satisfy themselves that Lela was of sound and disposing mind when she executed the will. Still, the chancellor admitted the will to probate, and the contestants appealed, raising numerous issues. Upon review of the matter, the Supreme Court concluded that because the two subscribing witnesses did not satisfy the legal requirements of "attesting" witnesses. The Court reversed the chancery court's ruling, and rendered a decision in favor of the contestants. View "In The Matter of The Estate of Lela W. Holmes" on Justia Law

This case concerned whether preneed contracts for funeral services were unilaterally transferable by customers from the original service provider, Waller Funeral Home (Waller), to another service provider, Coleman Funeral Home (Coleman). Customers who had contracted with Waller had prepaid the costs of their funeral services and merchandise, and Waller had placed their money in a trust maintained by the Mississippi Funeral Directors Association ("the Trust"). Coleman, along with Aubrey Parham, who previously had contracted with Waller for prepaid funeral services, filed a declaratory action asking the trial court to find that the prepaid funeral services contracts issued by Waller to its customers were unilaterally transferable by those customers to Coleman. Waller filed a counterclaim that alleged tortious interference with its contracts, false advertising, and defamation. Waller argued in its motion for partial summary judgment, and the trial court agreed, that the contracts were valid, enforceable, irrevocable and nontransferable, and, thus, granted Waller’s motion. Ultimately, the jury found in favor of Waller on all issues presented at trial and awarded both actual and punitive damages. Post-trial, upon the motion of Coleman, the circuit court reduced the punitive damages to $0 due to Coleman’s representation to the court that it had a negative net worth. Waller was awarded attorneys’ fees. Both parties have appealed the trial court’s final judgment. Upon review, the Supreme Court found that the trial court erred in allowing Waller to adduce speculative evidence about its alleged damages (future lost profits) for its contracting customers who are living, for whom no goods or services have been provided, on behalf of whom no payment from the Trust has been made to Coleman, and whose preneed funeral services contracts with Waller were found to be valid, binding, and nontransferrable. Accordingly, the Court remanded the case for a new trial on damages. View "Coleman & Coleman Enterprises, Inc. v. Waller Funeral Home" on Justia Law