Justia Mississippi Supreme Court Opinion Summaries

A jury convicted Sherwood Brown of one count of capital murder and two counts of murder and sentenced him to death. The Court granted Brown’s successive petition for post-conviction relief and allowed Brown to proceed in the trial court on his claim that he was mentally retarded and exempt from execution. After a hearing, the trial court held that Brown had failed to prove by a preponderance of evidence that he was mentally retarded. Brown appealed. The Supreme Court affirmed, finding that the trial judge heard the testimony, considered the testimony and evidence presented, followed the applicable case law procedure, and applied the correct legal standard for determining whether Brown was mentally retarded. Giving deference to the trial judge as the finder of fact, the Supreme Court affirmed the trial court's decision. View "Brown v. Mississippi" on Justia Law

A nursing home employee filed a wrongful-discharge suit more than a year after she claimed she was fired for reporting suspected patient abuse. Although wrongful-discharge suits in Mississippi generally must be based upon written employment contracts, she the employee claimed her suit falls under the public-policy exceptions this Court announced in "McArn v. Allied Bruce-Terminix Co., Inc" The issue this case presented for the Supreme Court's review was whether (as the employee argued) her wrongful discharge suit was governed by the general three-year statute of limitations governing torts, or (as the nursing home argued) it was governed by the one-year statute of limitations applicable to unwritten employment contracts. The trial court held "McArn" wrongful discharge claims are tort actions, subject to the general three-year statute of limitations. The Supreme Court agreed. View "Community Care Center of Aberdeen v. Barrentine" on Justia Law

Greater Fairview Missionary Baptist Church’s pastor, Danny Ray Hollins, was placed on paid administrative leave after he was accused of inappropriate sexual contact with a minor. The church decided to hold a vote on whether to retain Hollins as pastor. That vote originally was scheduled to take place in early 2013. But tensions arose in the church about Hollins’s status, giving rise to a “chaotic situation,” and the vote did not take place as planned. Instead, the church voted to allow the Deacons’ Ministry to form a legal committee and to hire outside legal counsel for assistance in resolving the internal conflict. On March 1, 2013, the day before the vote, Hollins filed a petition with the Chancery Court seeking “to enjoin any unauthorized and improper meetings and/or actions taken outside a properly called membership meeting.” The petition named the church and five deacons as defendants. Hollins asserted that the church planned to have a meeting on March 2 “to vote on a resolution discharging [him] as pastor.” He claimed that the vote would be invalid because (1) “there ha[d] been no certification of the list of members in good standing who would be entitled to vote . . .”; (2) absent such certification, adequate notice to eligible members could not be accomplished; and (3) the state denominational guidelines had not been followed because “there ha[d] been no attempts at Conciliation or other notice given to Plaintiff as pastor as required.” Hollins also claimed that he would be irreparably harmed if he was “voted out as Pastor,” in that his reputation would suffer, he would lose his income, and he would suffer emotionally. Finally, Hollins asserted that there was “a high likelihood [that he would succeed] in the merits of his case, namely that any meeting of church membership without proper certification of voter rolls and notice and adherence to all established guidelines is void . . . .” Hollins’s counsel certified that a temporary restraining order (“TRO”) was needed, that he had been unable to notice the defendants, that the defendants would not be prejudiced by the TRO, and that on “information and belief [the church] is not represented by counsel duly hired by the church membership.” The chancellor issued the TRO, "apparently without reading it." Five deacons and the church were named as defendants, the TRO was served on only four of the deacons (the agent for service of process for the church was deceased and could not be served). The TRO purported to enjoin “any membership meeting,” but the chancellor later explained it was intended to “restrain any vote that may take place.” The chancellor issued the TRO, but the church voted anyway and dismissed Hollins. The chancellor then vacated the vote and ordered the church to conduct another vote, this time with certain court-ordered procedures regarding notice, eligibility, vote-counting, and security. The Supreme Court granted the defendants’ motion for interlocutory appeal, and vacated Chancery Court’s orders in this case. Because Hollins’s request for a TRO presented a purely ecclesiastical controversy, the chancery court was without jurisdiction to hear it. As such, the Chancery Court erred in issuing the TRO and in vacating the vote and ordering a new one. View "Greater Fairview Missionary Baptist Church v. Hollins" on Justia Law

Lamar County wanted to withdraw from the Pat Harrison Waterway District, but a dispute arose over how much money the County needed to pay to get out. The chancery court found that Lamar County owed $337,088, excluding the District’s perpetual park operating and maintenance obligations as “contractual obligations . . . that are outstanding” under the statute. Finding no reversible error with the chancery court's decision, the Supreme Court affirmed. View "Pat Harrison Waterway District v. Lamar County" on Justia Law

Willie Kinzie sued Belk Department Stores, L.P., Belk, Inc., David Flowers, Shanay Grant, Kathy Coffey, Donald Smith, Nikki Daggins, Ray Faja, Staffmark Investment, LLC, and John Does 1-5 (Belk Defendants) for injuries he sustained while unloading a trailer that had transported merchandise to a Belk retail store. The trial court dismissed Kinzie’s lawsuit with prejudice, finding that Kinzie had misrepresented his injuries during discovery. The Court of Appeals reversed the judgment of the trial court and remanded the case, holding that Kinzie had not misrepresented his injuries and that the ultimate sanction of dismissal with prejudice was not warranted. "Dismissal is appropriate only under the most extreme circumstances and only where lesser sanctions will not suffice." The Supreme Court, after review, concluded that this was not an extreme case, and lesser sanctions could deter misleading responses without dismissing Kinzie’s claims altogether. The Court therefore affirmed that portion of the judgment of the Court of Appeals which held that dismissal with prejudice was not warranted. However, the Court reversed the Court of Appeals’ finding that the trial court abused its discretion when it determined that Kinzie had committed a discovery violation. The Court reversed the circuit court's judgment and remanded the case for trial. View "Kinzie v. Belk Department Stores, L.P." on Justia Law

Defendant-appellant Lawrence Byrd appealed his conviction for manslaughter and the twenty-year sentence he received. Byrd's appellate counsel certified to the Supreme Court that the record presented no arguable issues for appeal, but filing pro se, defendant argued that he received ineffective assistance of counsel, and that the evidence was insufficient to support his conviction. Finding no merit to any of defendant's issues on appeal, the Supreme Court affirmed his conviction and sentence. View "Byrd v. Mississippi" on Justia Law

Carl Cook was convicted of misdemeanor driving under the influence (“DUI”), first offense. Cook appealed to the County Court of Rankin County. At a trial de novo before the county court, Cook’s counsel moved to dismiss the case, claiming that the investigatory stop which led to Cook’s arrest was an illegal search and seizure because it was based on an anonymous tip that lacked sufficient indicia of reliability. The county court denied the motion and entered a judgment of conviction. Cook then appealed to the Rankin County Circuit Court, and the circuit court affirmed the county court’s conviction. Cook appealed his conviction to the Supreme Court, and the case was assigned to the Court of Appeals. Finding that the investigatory stop was legally justified, the Court of Appeals affirmed the judgment of the Circuit Court of Rankin County. Having granted Cook’s Petition for Writ of Certiorari, the Supreme Court took up the issue of whether the stop violated Cook’s Fourth Amendment right to be free from unreasonable searches and seizures. The Supreme Court concluded the Court of Appeals erred in finding that reasonable suspicion to stop Cook existed in this case. The judgments of the Court of Appeals and the Rankin County Circuit Court affirming Cook’s conviction were both reversed. Without the evidence gathered as a result of the stop, the evidence against Cook was insufficient to sustain a DUI conviction. As such, the Supreme Court reversed and rendered a judgment of acquittal. View "Cook v. Mississippi" on Justia Law

A jury convicted Ronald Hartfield of conspiracy to murder his wife but acquitted him of her murder. The circuit court sentenced Hartfield to twenty years in the custody of the Mississippi Department of Corrections. Hartfield appealed. The Court of Appeals reversed and remanded for a new trial based on the trial court’s exclusion of a coconspirator’s letters offered as statements against her penal interest. The Supreme Court granted the State’s petition for certiorari to address that issue. After review, the Court found that the letters were not against the coconspirator’s penal interest and that they were properly excluded by the trial court. Because the Court of Appeals did not address Hartfield’s arguments on the weight and sufficiency of the evidence and the trial court’s denial of one of Hartfield’s peremptory challenges, the Court ruled on those issues: (1) the trial court’s denial of the peremptory challenge was not clearly erroneous; (2) the evidence was sufficient to support Hartfield’s guilt of conspiracy; and (3) that the verdict of guilt was not against the overwhelming weight of the evidence. Therefore, the Supreme Court reversed the judgment of the Court of Appeals and reinstated and affirmed the judgment of the circuit court. View "Hartfield v. Mississippi" on Justia Law

Jerome Totten was tried and convicted in 2013 for burglary of a dwelling and grand larceny. He was sentenced as a habitual offender to terms of twenty-five and ten years respectively, to be served concurrently. Totten argued on appeal that the State failed to present sufficient evidence that the actual fair market value of the items stolen in the burglary equals or exceeds $500, thereby not supporting the conviction for grand larceny. After review, the Supreme Court held that the circumstantial evidence presented of the value of the items was sufficient for a reasonable jury to infer that the value of the items equaled at least $500. Totten also filed a pro se supplemental brief, challenging his burglary conviction in addition to the conviction for grand larceny. The Supreme Court found no merit to his challenge, and therefore affirmed his convictions. View "Totten v. Mississippi" on Justia Law

In 1982, Antonio Williams pled guilty to two counts of burglary. The trial judge sentenced him to three years' imprisonment on one count, and five years' imprisonment on the other. Then, in 1987, a jury convicted Williams of murder. The trial judge sentenced him to life without parole as a habitual offender under Mississippi Code Section 99-19-81, based on his two prior burglary convictions. The Mississippi Supreme Court affirmed Williams' murder conviction in 1990. In 2012, Williams filed a motion for post-conviction relief, for the first time challenging his burglary convictions. Williams argued that "during the entry of his guilty pleas," he was "denied his Sixth Amendment right to the effective assistance of counsel." Specifically, Williams argued that his counsel failed to inform him of an alleged speedy-trial violation before advising him to plead guilty to one of the counts. Williams also argued that his trial counsel "used coercion by promising [him] a suspended sentence" in the second count, when a suspended sentence allegedly was not statutorily available. Williams concluded that, because of the alleged Sixth Amendment violation, his guilty pleas could not "be considered to have been given voluntarily and intelligently." The circuit judge summarily denied Williams' motion, stating that "it plainly appears from the face of the motion, exhibits and prior proceedings in this case, that [Williams] is not entitled to post-conviction collateral relief." The circuit judge did not elaborate on his reasons for the denial, but the Supreme Court gathered from the language of his order that the denial was on the merits. It was also clear to the Court that from Williams' motion that he was challenging his burglary convictions and not his murder conviction. Rather than reviewing Williams' appeal on the merits, the Court of Appeals found that the circuit court had lacked jurisdiction to entertain Williams' motion, because he had not obtained permission from the Supreme Court prior to filing there. As such, the Court of Appeals found that it, too, lacked jurisdiction and dismissed Williams' appeal. After review, the Supreme Court agreed with Williams that the circuit court had jurisdiction to hear his motion, but found that the circuit judge did not err when he denied it. View "Williams v. Mississippi" on Justia Law