Justia Mississippi Supreme Court Opinion Summaries

Gregory Hopkins was convicted as a habitual offender of possession of cocaine with intent to distribute. On appeal he challenged the sufficiency and the weight of the evidence as well as the admission of evidence of his prior bad acts. Finding no error, the Supreme Court affirmed.View "Hopkins v. Mississippi" on Justia Law

A jury convicted Charles Ervin (a convicted felon) of armed robbery and as a felon in possession of a handgun following the armed robbery of the Healthy Body Store. Police were able to identify Ervin as a suspect after his brother, also a convicted felon, pointed the police in his brother’s direction. At trial, the trial court gave a flight instruction over Ervin's objection. The trial court sentenced him and included a gun enhancement in the sentencing. This appeal followed. Because the trial court improperly limited the defense’s cross-examination of a key State witness, the Supreme Court reversed Ervin’s convictions and remanded the case to the trial court for a new trial.View "Ervin v. Mississippi" on Justia Law

Carla Darnell and William Duff Darnell (“Duff”) were married in 2004 and divorced in 2012. The couple had one child, a son, C.D., in 2006. While the divorce was pending, C.D. exhibited behaviors which may have suggested sexual abuse. Duff denied any abuse, and investigations by the Department of Human Services did not substantiate abuse. No charges were filed against Duff. Carla sought a temporary protective order and consulted with a child-abuse expert who determined that C.D. exhibited behaviors that were indicative of abuse. Carla sought sole physical custody of C.D. Instead, the chancellor granted physical custody of C.D. to Duff, stating that Carla had been the one pursuing the child-abuse allegations when it was clear that none had occurred and that the Albright factors weighed in favor of Duff. Carla appealed. Upon review, the Supreme Court reversed the chancellor’s decision and remanded the case for new findings of fact and conclusions of law which take into account some of C.D.’s statements, which were not admitted at trial. View "Darnell v. Darnell" on Justia Law

Eric Moffett was convicted of capital murder and sentenced to death by a jury. Moffett was convicted of a savage sexual assault on a five-year-old girl, resulting in her death. Moffett’s conviction and sentence were affirmed by the Supreme Court on direct appeal, and his motion for rehearing was subsequently denied. Moffett presented a motion, an amended motion, and a supplemental motion seeking post-conviction relief. Moffett's argument to the Supreme Court was focused primarily on ineffective-assistance-of-counsel claims, but finding to merit to any of them, the Supreme Court denied relief. View "Moffett v. Mississippi" on Justia Law

Plaintiffs filed a wrongful death suit against Illinois Central for the death of their father. The case was dismissed because the three-year statute of limitations had run. Plaintiffs appealed, claiming that the statute of limitations had not expired, because it was tolled while the first suit, filed by the plaintiffs’ mother, was pending. Upon review, the Supreme Court affirmed the trial court’s dismissal of the case on the grounds that, because the doctrine of equitable tolling did not apply, the statute of limitations had expired by the time plaintiffs filed the second complaint. View "Burch v. Illinois Central Railroad Company" on Justia Law

Robert Reeves, an employee of Illinois Central Railroad, sued Mississippi Valley Silica, Inc. for lung injuries that allegedly were caused by his inhalation of silica while employed with Illinois Central. The case was dismissed without prejudice in 2006, and this suit was filed against thirty-two named defendants in 2007. Robert Reeves died in 2010, before the litigation was concluded, and the case then was pursued by his wrongful death beneficiaries. After trial in May 2012 against the sole remaining defendant, Valley, the jury found economic damages in the amount of $149,464.40 and noneconomic damages of $1.5 million, with Valley 15% at fault. The jury also awarded punitive damages of $50,000, and the trial court awarded attorney fees of $257,701.50. Although Valley was found only 15% at fault, the trial court determined that the law in place in 2002, when the original complaint was filed, should have applied. Accordingly, the statutory caps on punitive and noneconomic damages enacted in 2004 were inapplicable and Valley was jointly and severally liable for 50% of the judgment. Ultimately, the court determined that Valley owed the Reeves beneficiaries $824,732.20, plus $50,000 in punitive damages, and $257,701.50 in attorney fees, for a total of $1,132,433.70. Valley appealed. Upon review of the matter, the Supreme Court concluded that plaintiff failed to present sufficient evidence to identify Valley’s sand as the proximate cause of Robert Reeves’s injuries as a matter of law. Therefore, the Court reversed the trial court and rendered judgment in favor of Mississippi Valley Silica. View "Mississippi Valley Silica Company, Inc. v. Reeves" on Justia Law

Scott Smith was convicted of capital murder for the death of seventeen-month-old child and sentenced to life without the possibility of parole. Smith appealed his conviction to the Court of Appeals, arguing that the trial court erred in admitting several Facebook messages and that the testimony of an investigator violated the Confrontation Clause. The Court of Appeals found no reversible error and affirmed. Smith then appealed to the Supreme Court arguing that the Court of Appeals erred: (1) in holding that the Facebook messages were sufficiently authenticated; (2) that the Court of Appeals erred by finding that an email from Facebook was not inadmissible hearsay; and (3) that the Court of Appeals erroneously applied a harmless-error analysis to the violation of Smith’s confrontation rights. The Supreme Court granted certiorari and limited its review to Smith’s claim that the Facebook messages were not sufficiently authenticated. The Court found that Smith’s claim had merit; however, because the error was harmless, the Court affirmed Smith’s conviction and sentence.View "Smith v. Mississippi" on Justia Law

Levon Flowers made a workers' compensation claim against his former employer Crown Cork & Seal USA. The Supreme Court granted Crown’s petition for certiorari to review the compensability of a foot injury Flowers sustained in 2007. The Workers’ Compensation Commission denied Flowers’s request for permanent disability benefits for this injury and awarded temporary total disability benefits for the period between the injury and the date Flowers was cleared by his doctor to return to work. The Court of Appeals reversed, finding that Flowers was entitled to receive temporary total disability benefits until he reached maximum medical improvement (MMI) for his foot injury, which had not yet been determined by his doctors. Upon review, the Supreme Court found that the Court of Appeals reached the correct result in this case, but the Supreme Court reached that conclusion based on different precedent. The record in this case reflected that Crown refused to reinstate or rehire Flowers after his doctors released him to return to work. There was also evidence that Flowers underwent an unsuccessful search for alternative employment after Crown refused to rehire him. However, the ALJ and the Commission did not determine when Flowers reached MMI for his foot injury. From the testimony of Flowers' doctor, Flowers had not yet reached MMI as of January 14, 2008. Therefore, this case was not controlled by the Court's holding in "Jordan:" "[the Court] reiterate[d] that it is a primary duty of the Commission to analyze the evidence and determine whether and when a claimant has reached MMI. [. . .] After determining when Flowers reached MMI for his foot injury, the Commission must decide from the evidence presented whether Flowers is entitled to permanent disability benefits." View "Flowers v. Crown Cork & Seal USA, Inc." on Justia Law

Charles Ferguson rode as a back-seat passenger with Lazeric Yarbrough and Oratio Robinson, unaware of Yarbrough’s and Robinson’s intent to purchase marijuana once the car arrived in West Point. On their return to Starkville, the men approached a Mississippi Highway Patrol checkpoint. As they approached the checkpoint, Yarbrough (in the front seat) opened the door and threw the bag of marijuana from the vehicle. The officers at the checkpoint watched as the bag was thrown from the vehicle and subsequently arrested all three men. Ferguson was indicted for possession of marijuana in an amount greater than 250 grams but less than 500 grams, with the intent to distribute. The State presented that it had learned during the break that Ferguson was a habitual offender, and it had just then filed its motion to amend the indictment to reflect his habitual-offender status. The trial court moved forward with a hearing on the State’s motion to amend the indictment. Defense counsel argued that, because of the timing of the motion, an amendment would unfairly prejudice Ferguson. The trial court recessed to give defense counsel an opportunity to speak with Ferguson; during the recess, the State communicated its plea offer to Ferguson for his consideration. Thereafter, the trial court allowed the amendment. An additional “brief recess” was taken to give Ferguson and defense counsel one last chance to confer. Ferguson chose to reject the State’s plea offer. Ferguson was convicted of the lesser-included offense of possession of marijuana in an amount of 250 grams but less than 500 grams, and sentenced to serve eight years as a habitual offender. On appeal, he argued that: (1) the verdict was against the sufficiency of the evidence; (2) the trial court erred in allowing the indictment to be amended after jury selection had been completed; (3) the trial court erred in denying his motion for a continuance; and (4) his counsel was ineffective. The Supreme Court concluded after review, the trial court erred in allowing the amendment to the indictment, because Ferguson did not receive proper notice and was unfairly surprised. Accordingly, the Court reversed in part the judgments of the Court of Appeals and trial court that ruled otherwise. The Court vacated only the portion of Ferguson’s sentence that was based on his status as an habitual offender. The case was remanded for resentencing.View "Ferguson v. Mississippi" on Justia Law

Derrick Henley appealed his conviction by jury of possession of burglary tools. Upon review, the Supreme Court found that the State failed to present sufficient evidence that the tools were intended to be used in aiding the commission of a burglary. The Court therefore reversed and remanded Henley's conviction and sentence. View "Henley v. Mississippi" on Justia Law