Justia Mississippi Supreme Court Opinion Summaries

Charles Blackmon and Dexter Booth sued Malaco, Inc.; N.J. Pockets, Inc.; and Callop Hampton (owner of Hamp’s Place Night Club) on a premises-liability claim. Plaintiffs settled with Malaco. At trial, the jury returned a verdict in favor of Hampton. Hampton filed a post-trial motion, requesting the trial court to impose sanctions against Blackmon, Booth, and their attorney for filing a frivolous lawsuit and to award attorney fees. The motion was denied, and Hampton appealed that judgment to the Supreme Court. Finding no abuse of discretion, the Supreme Court affirmed. View "Hampton v. Blackmon" on Justia Law

Because Rudy Quilon was homeless following his release from prison, defendant Harvill Richardson permitted Quilon to move into his home while he got back on his feet. Over the next five months, Quilon "became increasingly unwelcome" as he bragged about having been convicted for murder and armed robbery, his previous experiences as a gang member, and killing a “snitch” in prison. On numerous occasions, Richardson attempted to persuade Quilon to leave the home, but Quilon claimed that he could not leave because he had no transportation or place to go. The situation culminated when Quilon, who had begun watching pornography on Richardson’s computer, stated that he wanted to have sex with Richardson’s wife. Despite having been asked to leave, Quilon refused and walked out to a shed behind the home where Richardson kept axes and other tools that could be used as weapons. Richardson armed himself with a pistol. As Quilon returned from the shed, he approached Richardson in a threatening manner, with one arm concealed behind his back. Quilon kept coming toward him, so Richardson shot Quilon in the stomach. Richardson was prodecuted for murder. The trial judge ruled in limine that Richardson would not be allowed to support his self-defense claim with evidence of the victim’s prior bad acts, including a violent criminal history. Because Richardson's knowledge of this evidence would be highly probative of the reasonableness of his conduct and fear of the victim, the Supreme Court reversed and remanded the case for a new trial. View "Richardson v. Mississippi" on Justia Law

While driving one day in 2005, Kathryn Loyacono observed Watacha Shelby backing her car toward Loyacono on the same road. Loyacono brought her vehicle to a stop, but Shelby backed into the front of her vehicle. Following the accident, Loyacono proceeded by ambulance to the emergency room, complaining of neck and back pain. She was released the same day after being diagnosed with a muscle strain. At the time of the accident, Shelby lacked liability insurance, but Loyacono held an uninsured-motorist policy through Travelers Insurance. Accordingly, Loyacono filed suit against Shelby and Travelers, seeking to recover the policy limit of $2.5 million. Prior to trial, the circuit judge entered an order acknowledging that the parties had stipulated that Shelby had proximately caused the accident and that the Travelers policy covered any injuries Loyacono suffered, and proceeded to trial on injury and causation. The jury awarded plaintiff zero dollars. The Mississippi Court of Appeals found that the jury’s determination of damages conflicted with the overwhelming weight of the evidence. The Supreme Court disagreed, but affirmed the Court of Appeals’ decision to reverse and remand for a new trial on damages because the trial judge admitted irrelevant and highly prejudicial evidence of the plaintiff’s husband’s income. View "Loyacono v. Travelers Insurance Company" on Justia Law

Defendant Joe Cotton was convicted of murder for the shooting death of Fannie Lee Burks. He appealed his conviction, challenging the sufficiency and the weight of the evidence. Finding no error, the Mississippi Supreme Court affirmed defendant's conviction and sentence. View "Cotton v. Mississippi" on Justia Law

Roger Gillett was convicted of two counts of capital murder for which he was sentenced to death. Gillett petitioned for post-conviction relief, raising six issues for the Supreme Court's review: (1) the underlying capital-murder aggravator of robbery was improperly expanded; (2) conviction of capital murder under the “continuous-action doctrine” was unconstitutional; (3) Gillett’s trial counsel was ineffective in failing to investigate Gillett’s background and to present an adequate mitigation case; (4) Gillett’s trial counsel were ineffective in failing to object to prosecutorial misconduct during the sentencing portion of his trial; (5) Gillett’s due-process rights were violated when the Mississippi Supreme Court reweighed the aggravating and mitigating factors; and, (6) cumulative error. Upon review of the briefs submitted by Gillett and the state, the Supreme Court found issues one and two were without merit; however, under issue five, Gillett’s due-process rights were violated in sentencing. Therefore, the Court granted Gillett’s petition in part and denied in part, vacated his death sentences and remanded the case to the circuit court for a new sentencing hearing. View "Gillett v. Mississippi" on Justia Law

After receiving a diagnosis of mesothelioma, Russell Nix filed suit against Union Carbide based on his exposure to its asbestos products. A jury returned a verdict for Nix on his inadequate warning claim, awarded Nix $250,000 in compensatory damages and $500,000 in punitive damages. The trial court then awarded Nix nearly $500,000 in attorney’s fees and costs. Union Carbide appealed. Upon review of the trial court record, the Mississippi Supreme Court affirmed the jury’s award of compensatory damages, reversed the jury’s award of punitive damages, vacated the award of attorney’s fees, and remanded the case for a new trial on punitive damages. View "Union Carbide Corporation v. Nix" on Justia Law

After observing LaMarcus Butler turn off the lights of his vehicle and make a u-turn in an apparent effort to avoid a police roadblock, police pursued Butler, at varying speeds, until a superior officer instructed him by radio to desist. The fleeing Butler collided with a vehicle occupied by Margaret Stephens, Lee B. Lewis, and Oda Mae Green. Stephens died as a result of the crash, and Lewis and Green suffered severe injuries. Plaintiffs Lewis and Green, individually, and Sonya Stephens, on behalf of Margaret Stephens’s wrongful-death beneficiaries, filed suit against the City of Jackson, Mississippi. Following a bench trial in 2008, the trial court assessed 100% of the fault to the City and entered judgment in favor of the Plaintiffs. The Court of Appeals reversed and remanded the circuit court’s holding, finding that police had not acted in “reckless disregard for the safety and well-being of persons not engaged in criminal conduct,” and therefore, governmental immunity shielded the City from liability. Plaintiffs appealed to the Supreme Court, asserting that the Court of Appeals: (1) misinterpreted the factors for determining reckless disregard by law enforcement personnel; (2) improperly weighed the evidence on appeal, made credibility determinations, and improperly rejected evidence that supported the findings of the trial court; and (3) improperly substituted its judgment for the trial court’s credibility determination regarding expert testimony. Upon review, the Supreme Court found dispositive the question of whether the Court of Appeals misinterpreted and misapplied case law for determining reckless disregard by law enforcement officers. Finding that the Court of Appeals erred, the Supreme Court reversed its judgment, and reinstated and affirmed the circuit court's judgment. View "City of Jackson v. Lewis" on Justia Law

Timothy Pryer sought from the circuit court: “the Order givin[g] Carol Gates the Office of Judge de facto or pro tempore and the order givin[g] Carol Gates authority to appoint indigent counsel for December 2, 2004 [hearing] and the names of the 40 plus souls and their addresses according to the record.” The Itawamba County Circuit Court issued an order “denying Pryer records and construing a request for records as a petition for Post-Conviction Relief (PCR)." Pryer then filed a petition for writ of mandamus to the Supreme Court, requesting that it direct the circuit judge to enter an order on a “Motion to Show Cause.” The Supreme Court granted the petition for writ of mandamus, and the circuit court proceeded to enter an order that denied Pryer’s motion, explaining that the documents requested were “not contained with the Circuit Clerk’s file” and that “[t]his motion contains the exact same requests as the previously filed motions.” The court continued, “the Motion to Show Cause contains completely unfounded and slanderous allegations against several court officials.” The Court of Appeals affirmed the judgment of the Itawamba County Circuit Court, holding that “we have no reason to believe that any such documents do exist. It further appears that Pryer is merely on a ‘fishing expedition’ for grounds upon which to attack his conviction and sentence.” Finding no reversible error, the Supreme Court affirmed the appellate court's decision. View "Pryer v. Mississippi" on Justia Law

LeDarius Bonds was convicted by jury of murder and sentenced to life in prison. Bonds appealed his conviction, arguing that the trial court erred in admitting "Exhibit 39," a gruesome photograph that he contended was more prejudicial than probative, and that the trial court erred in allowing a jury instruction which informed the jury that it could infer malice from the use of a deadly weapon. Finding that Exhibit 39 was far more prejudicial than probative, the Supreme Court reversed the conviction and remanded for a new trial.View "Bonds v. Mississippi" on Justia Law

James Forbes settled a personal-injury action while he was represented by Louis St. Martin. Forbes later sued St. Martin, challenging the validity of his contingency-fee arrangement and the associated attorneys’ fees. The Chancery Court granted summary judgment to St. Martin; the Court of Appeals reversed the chancery court’s decision and remanded the case for further proceedings. Upon review of the matter, the Supreme Court reversed the Court of Appeals’ judgment, finding that summary judgment in favor of St. Martin was proper. View "In the Matter of the Estate of Louis St. Martin, Deceased: Forbes v. Hixson" on Justia Law