Justia Mississippi Supreme Court Opinion Summaries

Tamra Stuckey was shot and killed on the couch in Charles Kuebler’s apartment in the early morning hours of June 30, 2010. Tamra had been staying at Kuebler’s apartment for three or four days prior and had shown an unreciprocated romantic interest in Kuebler at that time. The trial court allowed the State to introduce evidence of Kuebler’s flight from custody in July 2011, approximately ten months after he was released on bond. The jury returned a verdict finding Kuebler guilty of deliberate-design murder, and the trial court sentenced him to life in prison. In December 2011, Kuebler filed a motion for a judgment notwithstanding the verdict or, in the alternative, a new trial. After a hearing, the trial court denied the motion in October 2012. Kuebler timely appealed. The Court of Appeals found error with the admission of evidence of Kuebler’s flight and the related jury instruction but held that it was harmless error and affirmed Kuebler’s conviction and sentence. After its review, the Supreme Court found that the trial court committed reversible error by denying Kuebler the opportunity to present his theory of defense, in granting a flight instruction, and by prohibiting Kuebler from offering evidence to rebut the State’s argument that his flight indicated consciousness of guilt. Accordingly, the appellate court was reversed and the matter remanded for a new trial. View "Kuebler v. Mississippi" on Justia Law

Travaris Christian was convicted on two counts of capital murder (underlying felony of robbery); one count of house burglary, conspiracy to commit house burglary, felonious child neglect, and felon in possession of a firearm. Christian appealed, claiming his constitutional rights to confrontation were violated; his convictions were supported by insufficient evidence; and the trial court erred in granting the State an aiding-and-abetting instruction and denying him an abandonment instruction. Finding no merit in any of the issues raised, the Mississippi Supreme Court affirmed Christian’s convictions. View "Christian v. Mississippi" on Justia Law

The underlying lawsuit to this appeal concerned two automobile accidents that occurred on Interstate 55 North in Grenada County on the evening of Thursday, May 24, 2012. The first accident involved David Williams and Brian Spurlock: Williams was traveling in a tractor-trailer leased to RWI Transportation, LLC. The left side of the trailer contacted the right side of a Ford Ranger pickup driven by Spurlock. Spurlock's truck overturned. Williams pulled the trailer over to the shoulder of the highway on an offramp to Exit 206. The second accident involved George Ready, II, and a UPS tractor-trailer driven by Shannon Carroll. The Ready accident occurred nearly three quarters (3/4) of a mile south of the Williams accident. Approximately 730 feet north of the ramp to the Exit 206 overpass, Ready collided with the rear of a of the UPS tractor-trailer driven by Carroll. The UPS tractor-trailer was stopped in the right hand northbound travel lane where it had been forced to stop as a result of backed-up traffic from the Williams accident. Ready filed suit against RWI and Williams, alleging claims of negligence and negligent entrustment. RWI and Williams moved for summary judgment, arguing that Ready’s injury was not a foreseeable consequence of Williams’s accident, thus Ready could not establish that he was owed a duty by RWI and Williams. RWI and Williams were granted summary judgment. Ready appealed, but finding no error in the trial court’s grant of summary judgment, the Supreme Court affirmed. View "Ready v. RWI Transportation, LLC" on Justia Law

The State of Mississippi entered into a Public Trust Tidelands lease with the City of Bay St. Louis to build a municipal harbor on beachfront property. After the City began construction of the harbor, brothers Kenneth, Ray, and Audie Murphy filed an inverse condemnation action, claiming that the State and the City had taken and damaged their property without compensation. The case was tried and a jury ultimately found the State liable to the Murphys for $644,000 in damages. The State appealed. The State claimed true ownership of the property under the authority of the Tidelands Act, or alternatively, its sovereign power of eminent domain. There was no evidence in the record indicating that the City could have constructed the harbor without the State first exercising a claim of ownership over the property. Because the State’s claim of ownership ultimately converted private property to public use, the Supreme Court found that the jury acted reasonably in assessing the full amount of damages to the State. Therefore, finding no error, the Supreme Court affirmed the jury’s verdict. View "Mississippi v. Murphy" on Justia Law

Floyd McKee contested the election after he was defeated by Joe Chandler in the Democratic primary run-off election for District 5 Supervisor of Clay County. After the Clay County Democratic Executive Committee (CCDEC) ruled in favor of Chandler, McKee filed a petition for judicial review with the Clay County Circuit Court. Chandler filed a motion to dismiss McKee’s petition, arguing that it was not timely filed. This interlocutory appeal stems from the circuit court’s denial of Chandler’s motion to dismiss. Finding that the circuit court erred in failing to grant Chandler’s motion to dismiss, the Supreme Court reversed the circuit court’s judgment and remanded this case back to the circuit court with instructions to dismiss McKee’s petition for judicial review. View "Chandler v. McKee" on Justia Law

Donald Bell appealed his conviction and sentence for attempted armed robbery. The jury returned from deliberations and informed the court that they had failed to reach a unanimous decision. Learning the jury was split nine-to-three, the judge instructed them to go back and deliberate one more time. Prior to releasing them for further deliberations, he stated to the jury: "But I don’t want you going back there just being stubborn. Go back there with the seriousness of purpose because you came here to do a job and if we can get a unanimous decision from you, we would like to." Defense counsel immediately moved for a mistrial, arguing that the court’s comment “place[d] undue pressure on those three individuals at this point to make up - come to a decision when their consci[ence] didn’t allow them to issue a conclusion.” That motion was denied. The jury returned its verdict, and Bell was sentenced to a five-year term of imprisonment. The Supreme Court reversed, finding that the trial judge’s comments to the jurors before sending them back for further deliberations were impermissibly suggestive and capable of being interpreted as coercive. The case was remanded for a new trial. View "Bell v. Mississippi" on Justia Law

Brodrick Moody was found guilty of possession of a cell phone while he was incarcerated, for which he was sentenced to ten years, to run consecutively to the sentence he was already serving. Moody appealed, arguing the trial court erred in instructing the jury as to the applicable law and burden of proof. After review, the Supreme Court agreed that the trial court erred in instructing the jury and reversed Moody’s conviction on the cell phone offense, vacated his sentence, and remanded for a new trial. View "Moody v. Mississippi" on Justia Law

Larry Wells was convicted of possession of cocaine with intent to transfer and was sentenced as an habitual offender and a recidivist drug offender to sixty years in the custody of the Mississippi Department of Corrections. Wells appealed his conviction and sentence and the Mississippi Supreme Court affirmed the conviction but remanded the case for resentencing. On remand, the Circuit Court declined to apply the subsequent-drug-offender enhancement and reduced Wells’s sentence from sixty years to thirty years. Wells appealed, contending that the trial court’s refusal to sentence him under the amended version of the statute, which became effective before his resentencing, was erroneous. The Supreme Court affirmed the second sentence, finding that the statutory amendment occurred several years after the commission of the crime and after Wells’s initial sentencing. View "Wells v. Mississippi" on Justia Law

In 2003, the Mississippi State Tax Commission (now the Department of Revenue) assessed additional income tax, penalties, and interest in an amount greater than $11.75 million against AT&T based on its income from dividends from non-Mississippi subsidiaries. After exhausting its administrative remedies, AT&T appealed to the Chancery Court of the First Judicial District of Hinds County, arguing that a portion of Section 27-7-15(4)(i) discriminated against interstate commerce in violation of the negative, or dormant, aspect of the Commerce Clause of the United States Constitution. AT&T argued that the scheme allowed an income tax exemption for dividends received from AT&T’s Mississippi subsidiaries while denying an exemption to similarly situated non-Mississippi subsidiaries. Ultimately, the chancellor agreed and declared a portion of Section 27-7-15(4)(i) as unconstitutional. Having determined that the geographical limitation in Section 27-7-15(4)(i) offended the negative aspect of the Commerce Clause of the United States Constitution, the Mississippi Supreme Court held that portion of it to be unconstitutional and invalid. The phrase “under the provisions of this article” was struck from Section 27-7-15(4)(i) and the severance was be applied to AT&T for the tax years at issue in this case. The judgment of the Chancery Court was affirmed. View "Miss. Dept. of Revenue v. AT&T Corporation" on Justia Law

The Pascagoula-Gautier School District and the City of Pascagoula took issue with the Jackson County Board of Supervisors’ approval of the Tax Assessor’s methodology in assessing taxes on Chevron’s leasehold interest in property it leased from Jackson County. After several years of litigation, and after the trial court had denied two motions to dismiss for lack of standing, the trial court sua sponte reversed course and granted the second motion to dismiss for lack of standing, reasoning that the School District and City lacked standing because Mississippi Code Section 11-51-77 did not specifically grant them standing. Because the School District and the City did not need to show a specific statute authorizing standing, and because they otherwise demonstrated standing, the Supreme Court reversed the trial court judgment on this issue. View "Pascagoula-Gautier Sch. Dist. v. Bd. of Supervisors of Jackson County" on Justia Law