Justia Mississippi Supreme Court Opinion Summaries

Franklin Fitzpatrick was found guilty of the murder Sheriff’s Deputy Dewayne Crenshaw. He was sentenced to life in prison without the possibility of parole. He appealed his conviction and sentence, arguing: (1) the trial court erred in giving jury instruction that allowed for conviction without a proper showing of the requisite mental state; (2) the trial court erred when it overruled Fitzpatrick’s motion for new trial based on the weight of the evidence; and (3) the trial court erred in ruling Fitzpatrick was procedurally barred from challenging the elements jury instruction on appeal because he did not object to it at trial. Because the jury instruction was a correct statement of the law, and Fitzpatrick’s arguments were otherwise without merit, the Supreme Court affirmed Fitzpatrick’s conviction and sentence. View "Fitzpatrick v. Mississippi" on Justia Law

The Court of Appeals affirmed Timothy Carr’s conviction and sentence and denied his motion for rehearing. Carr twice sought leave from the Supreme Court to file motions for post-conviction relief (PCR) (first in May 2008, then in September 2010). The Supreme Court denied both applications. Carr filed a third application, which a panel of the Supreme Court granted in 2013. Carr then filed his PCR motion, claiming that the habitual-offender portion of his sentence should have been vacated for two reasons: (1) because the Supreme Court’s intervening decision in "Gowdy v. Mississippi," (56 So. 3d 540 (Miss. 2010)) prohibited post-conviction indictment amendments; and (2) because the prosecution failed to reintroduce evidence of his prior convictions during the sentencing phase of his trial. Carr does not here contest the validity or admissibility of his prior convictions. Finding that Gowdy did not apply to his case, the Supreme Court affirmed the Court of Appeals. View "Carr v. Mississippi" on Justia Law

This case was an interlocutory appeal stemming from a law suit by Mautrice Vaughn’s estate and wrongful-death beneficiaries against The Service Companies Inc., (“FSS”), following Vaughn’s fatal heart attack at work. Plaintiffs Vaughn’s estate and wrongful-death beneficiaries sued for false imprisonment and intentional infliction of emotional distress. The plaintiffs alleged Vaughn’s supervisor would not let her leave work to see a doctor despite complaints of severe chest pain and a headache. Following the denial of its Motion for Summary Judgment, the Supreme Court granted FSS leave to bring this interlocutory appeal. FSS argued the circuit court erred by finding a factual dispute existed as to whether FSS had “an actual intent to injure” for purposes of determining whether the Mississippi Workers’ Compensation Act exclusively governed plaintiffs’ claims. Upon review, the Supreme Court found plaintiffs’ common-law false-imprisonment claim was insufficient to survive summary judgment because the plaintiffs did not produce evidence of intent to detain. "The plaintiffs may not merely rest on the pleadings and allegations alone." The Court found summary judgment in favor of FSS proper, reversed the trial court’s ruling denying summary judgment, rendered judgment in favor of FSS finally dismissing plaintiffs’ complaint and this action with prejudice. View "The Service Companies, Inc. v. The Estate of Mautrice Vaughn" on Justia Law

John Franklin was found guilty of arson by jury, sentenced to eighteen years in the custody of the Mississippi Department of Corrections, ordered to pay a $1,500 fine, make restitution to the dwelling house owners, and make restitution to the victim. The court ordered that the fine and restitutions be made in monthly installments of $150, with the first payment due ninety days following Franklin’s release from confinement. Franklin appealed, arguing two issues: (1) the trial court erred in assessing restitution; and (2) the trial court erred in admitting Franklin’s confession into evidence. Finding no merit in either issue, the Supreme Court affirmed the trial court judgment. View "Franklin v. Mississippi" on Justia Law

Michael Taylor was convicted in 2012 of possessing stolen property. He was sentenced as a habitual offender to ten years in prison. Taylor testified in his own defense at trial. During cross-examination, the State questioned Taylor extensively about his numerous past felony convictions without objection from defense counsel. After review of the trial court record, the Supreme Court concluded that defense counsel’s failure to object to the inquiry into Taylor’s prior convictions constituted ineffective assistance of counsel. The Court reversed Taylor’s conviction and remanded for a new trial. View "Taylor v. Mississippi" on Justia Law

The City of Madison enacted an ordinance requiring landlords to obtain a license for each unit of rental property. The Rental Inspection and Property Licensing Act (RIPLA) conditioned the grant of a license on the landlord’s advance consent to property inspections. Kenneth Crook was convicted in municipal court of two counts of violating RIPLA by maintaining a rental unit without a rental license and sentenced to pay a fine of $300 on each count. After a bench trial, the County Court of Madison County affirmed. Crook then appealed to the Circuit Court of Madison County, which also affirmed. Crook then appealed to the Supreme Court. The Supreme Court assigned his appeal to the Court of Appeals, which affirmed. At each level of review, Crook argued that RIPLA’s inspection provisions violated the ban on unreasonable searches imposed by the Fourth Amendment of the United States Constitution. The Court of Appeals held that RIPLA was not unconstitutional because it required the City to obtain a judicial warrant if the landlord or tenant withheld consent to an inspection. The Supreme Court granted Crook’s petition for certiorari and reversed: RIPLA’s inspection provisions were constitutionally defective because, although RIPLA had a warrant provision, that provision allowed a warrant to be obtained “by the terms of the Rental License, lease, or rental agreement,” which was a standard less than probable cause. The Court reversed the lower courts' judgments affirming Crook's convictions, and rendered a judgment of acquittal. View "Crook v. City of Madison" on Justia Law

Ray Dillard attempted to collect workers' compensation benefits from the president and majority shareholder of his employer. In 1997, The Commission held that Dillard suffered a compensable injury. After the mandate issues, one of Dillard's attorneys filed a lis pendens notice regarding several parcels of real property the company's president owned. Because none of that property belonged to the company itself, Dillard's attorney informed the president that it was asking the Commission to hold the president personally liable for Dillard's benefits because the company failed to carry workers' compensation insurance. Dillard died in 2005 while unresolved issues regarding who would ultimately be responsible for Dillard's benefits was pending before an administrative law judge. Dillard's estate filed a complaint at the circuit court against the president and company, claiming that the company was required to carry workers' compensation insurance but failed to do so. Therefore, the Estate argued the president was personally liable for Dillard's benefits. Among other things, the president argued that the Estate's claim was barred by the statute of limitations and the doctrine of res judicata. Eventually, the administrative law judge granted the Estate's renewed motion for summary judgment, and entered a judgment of approximately $223,000 against the president and the company "jointly and individually." The president appealed, and the case was assigned to the Court of Appeals. The appellate court held that Dillard's claim against the company president was barred by res judicata and the statute of limitations. The Supreme Court held the Court of Appeals erred in reaching that conclusion, reversed and reinstated the trial court's judgment in favor of Dillard. View "Jarrett v. Dillard" on Justia Law

A jury convicted Vance Drummer of two counts of grand larceny and one count of attempted grand larceny in 2012. The trial court granted the State’s request for a flight instruction because Drummer, after absconding with the stolen goods, fled from police when they attempted to pull him over after he had run a stop sign in Mathiston. The trial court sentenced Drummer as an habitual offender pursuant to Mississippi Code Section 99-19-81. One of the felony convictions the State used to prove Drummer’s status as an habitual offender was the felony-fleeing conviction to which he pled guilty as a result of his flight from police in Mathiston. The Supreme Court found that the trial court erred when it sentenced Drummer as an habitual offender: "Drummer’s flight from police arose from the same nucleus of operative facts as the larcenies for which he was convicted and therefore should not have been used as a predicate felony pursuant to Section 99-19-81." Accordingly, Drummer’s sentence as an habitual offender was vacated, and ad the case remanded to the trial court for resentencing of Drummer as a nonhabitual offender. View "Drummer v. Mississippi" on Justia Law

Richard Chapman was serving a life sentence in the custody of the Mississippi Department of Corrections. He never had a direct appeal (through no apparent fault of his own), and his trial record allegedly has been destroyed. While Chapman filed multiple motions for post-conviction relief (PCR), no appellate court has ever addressed the merits of his claims, despite potential violations of his constitutional rights. Under these peculiar circumstances, the Supreme Court found that, in the interests of justice, Chapman was entitled to an evidentiary hearing so that he and the State have an opportunity to reconstruct his trial record. View "Chapman v. Mississippi" on Justia Law

Milton Harper, the managing partner and president of Banks, Finley, White & Company of Mississippi (“Banks”), suffered a severe stroke in August 2000, and died of another stroke in July 2001. His dependents sued Banks for workers’ compensation benefits. The administrative law judge and the Workers’ Compensation Commission held that Harper’s injuries and death arose out of the scope and course of his employment at Banks. On appeal, the circuit court agreed that substantial evidence in the record supported the Commission’s conclusion that Harper’s stroke arose out of his employment, but that court held that Harper’s dependents were barred from recovering workers’ compensation benefits because Harper had failed to obtain workers’ compensation insurance for Banks. In turn, the Court of Appeals in "Harper v. Banks, Finley, White & Co. of Mississippi," (136 So. 3d 462 (Miss. Ct. App. 2014)), held that Harper’s dependents were not barred from recovery because Section 71-3-79 of the Mississippi Code allowed members of partnerships to exempt themselves from workers’ compensation coverage by giving notice in writing. Because Harper had not opted out of coverage in writing, the Court of Appeals held that Banks was required to provide workers’ compensation benefits to Harper’s beneficiaries. On writ of certiorari, the Supreme Court affirmed in part, and reversed in part. The Court held that the Court of Appeals erred in applying Section 71-3-79 of the Mississippi Code to the facts of this case. Because Banks did not have workers’ compensation insurance coverage, there was no coverage for Harper to opt out of in writing as contemplated by Section 71-3-79. Instead, the Court held that Section 71-3-52 of the Mississippi Code controlled the analysis of this case: because Banks had more than five employees, it was required to obtain workers’ compensation insurance and provide workers’ compensation benefits to its employees. The Court affirmed the Workers’ Compensation Commission’s finding that Harper suffered a fatal injury through the course of his employment at Banks was supported by substantial evidence. View "Harper v. Banks, Finley, White & Co. of Mississippi, P.C." on Justia Law