Justia Mississippi Supreme Court Opinion Summaries

In a custody dispute between the natural father and the maternal grandmother, the chancellor granted custody to the father, finding that the father had not deserted his child. Although the grandmother had stood in loco parentis to the child since the mother’s death, the chancellor correctly recognized that this alone could not overcome the natural-parent presumption. Finding no error, the Supreme Court affirmed the chancery court's judgment. View "Davis v. Vaughn" on Justia Law

Lee Darrell Nix appealed a Court of Appeals judgment affirming the Circuit Court’s denial of his motion for post-conviction relief (PCR). Nix was convicted of touching a child for lustful purposes and kidnapping. His conviction was unanimously affirmed by the Supreme Court on direct appeal. On PCR, Nix argued that the State failed to prove beyond a reasonable doubt an essential element of the crime. The Supreme Court concluded that Nix failed to carry his burden showing he was entitled to relief. As such, the trial court did not err in denying his petition. View "Nix v. Mississippi" on Justia Law

Two vehicles struck multi-ton counterweights owned by Mitchell Crane Services, Inc., which were on a traveled portion of a highway. The accident occurred in 1999, at night. The occupants of the two vehicles sued Mitchell Crane. During the liability phase of a bifurcated trial, the jury found that a thief was seventy-five percent responsible, and Mitchell Crane was twenty-five percent responsible for any damages. The trial court denied Mitchell Crane’s motion for judgment notwithstanding the verdict (JNOV). At the conclusion of the damages trial, the jury returned a verdict in favor of Patricia Page and the other plaintiffs. Mitchell Crane renewed its motion for JNOV, which was denied. Mitchell Crane appealed, and Page cross-appealed. Given a jury finding that a thief stole the truck, the trial court erred by not applying our controlling law and granting Mitchell Crane’s original motion for JNOV. Accordingly, the Supreme Court reversed the trial court's judgment. View "Mitchell Crane Services, Inc. v. Page" on Justia Law

This appeal stems from a civil suit brought by the estates and wrongful-death beneficiaries of Christopher Allan Bloodworth, Steven Earl Tallant Jr., Marcus Richardson, and A.W. Hilson, four men killed at a railroad crossing when a freight train collided with the truck in which they were traveling. The beneficiaries of Bloodworth, Tallant, Richardson, and Hilson filed their complaint(s) against Illinois Central Railroad Company and several of its employees, including the track crew, as well as other employees of Illinois Central’s track department. Defendants filed two motions for summary judgment; the circuit court granted summary judgment in favor of Defendants with respect to Plaintiffs’ claims alleging negligent operation of the train. The circuit court also granted partial summary judgment in favor of Defendants on three of four contested issues regarding the engineering and maintenance of the railroad crossing, leaving one surviving claim. The circuit court then granted five of Defendants’ motions in limine to exclude Plaintiffs’ evidence. Finding that, without the excluded evidence, Plaintiffs could not support the remaining claim, the circuit court granted Defendants’ motions for summary judgment in their entirety and issued a judgment and certificate pursuant to Rule 54(b) of the Mississippi Rules of Civil Procedure. Plaintiffs appealed the trial court's decisions to the Supreme Court, and Defendants cross-appealed as to certain trial court rulings. Because the Supreme Court affirmed the trial court’s grant of summary judgment in favor of Defendants on each claim by Plaintiffs, the Court dismissed Defendants’ cross-appeal as moot. View "Estate of Bloodworth v. Illinois Central Railroad Company" on Justia Law

Yardley Shelton Lyons was indicted for carjacking (Count I) and kidnapping (Count II). The indictment accused Lyons of perpetrating these acts against persons over the age of sixty-five years, subjecting him to the elderly sentence enhancement which allowed the court to sentence him to twice the maximum statutory sentence for both counts. After finding Lyons guilty on both counts, the jury also found that he was eligible for the elderly sentence enhancement. The trial court did not impose the sentence enhancement, and instead sentenced Lyons to fifteen years for carjacking and twenty-five years for kidnapping, to be served consecutively. The court later amended Lyons's sentence on Count II, reducing it from twenty-five years to fifteen years. Lyons filed a motion for judgment notwithstanding the verdict (JNOV), or for a new trial. This motion was denied. Lyons appealed. After reading the entire transcript and record, the Supreme Court was unable to discern any issues which would warrant additional briefing or reversal. Accordingly, the Court affirmed Lyons' convictions and sentences. View "Lyons v. Mississippi" on Justia Law

Terence Jones appealed a Chancery Court's denial of his 2011 petition to disestablish paternity, which relied on Section 93-9-10(3)(c) of the Mississippi Code. Because Jones signed a stipulated agreement of paternity that was approved by court order in 2000, the chancery court properly denied Jones's petition as presented. Accordingly, the Supreme Court affirmed the chancery court's judgment denying Jones's petition. View "Jones v. Mallett" on Justia Law

Sacory Brown directly appealed his conviction for burglary of a dwelling to the Supreme Court. Brown received a twenty-five year sentence, with eighteen years to serve and seven years suspended (with five of those years on post-release supervision). On appeal, he argued that the Miranda warning he was given before making an inculpatory statement to the police was insufficient because it did not explicitly inform him of his right to stop talking to the police at any time. He also argued that the twenty-five-year sentence was grossly disproportionate in violation of the Eighth Amendment. Furthermore, he argued that the evidence supporting the verdict was legally insufficient and the verdict was against the overwhelming weight of the evidence. Finding no error, the Supreme Court affirmed Brown's conviction and sentence. View "Brown v. Mississippi" on Justia Law

Defendant Mickey Johnson argued that law enforcement officers gave defective Miranda warnings and coerced his written statement by promising to forego charges against his fiancée. Defendant was ultimately convicted for possession of cocaine. The Supreme Court found defendant's Miranda warnings were not defective, and was not persuaded that the trial court erred in finding defendant voluntarily gave a statement that included his confession. View "Johnson v. Mississippi" on Justia Law

A jury convicted Eboni White of manslaughter, and the trial judge sentenced her to twenty years in the custody of the Mississippi Department of Corrections (MDOC). White appealed, claiming the trial court erred by: (1) refusing to dismiss her indictment based on certain improper influences on the grand jury; (2) prohibiting her expert witness from giving his opinion at trial on the use of force in self-defense; (3) refusing to instruct the jury on her theory of self-defense; and (4) not allowing her witness to testify because he was in the courtroom during the expert's testimony. Additionally, White challenged the weight and sufficiency of the evidence to support her conviction and argued cumulative error. The Court of Appeals affirmed, finding no error. The Supreme Court granted certiorari on the issues of whether the trial court erred by excluding the witness' testimony and denying White’s jury instructions, the Court found error and reversed for a new trial. View "White v. Mississippi" on Justia Law

The issue before the Supreme Court in this case arose from an alleged breach of contract and bad-faith denial of Dr. Jack and Margaret Hoover’s homeowner’s insurance claim against United Services Automobile Association (USAA) following Hurricane Katrina. The trial judge granted USAA’s motion for directed verdict as to the Hoovers’ claims for: (1) the unpaid portion of losses; (2) mental anguish and emotional distress; and (3) punitive damages. The trial court further determined that there were issues of fact for the jury as to whether the Hoovers’ roof structure was damaged, and as to the Hoovers’ claim for additional living expenses. The jury found for the Hoovers and granted compensatory damages. The Hoovers appealed and USAA cross-appealed. After its review of the record, the Supreme Court found that trial court applied an incorrect legal standard and improperly shifted a burden of proof to the Hoovers. Therefore the Court reversed the directed verdict as to the unpaid damages, and remanded the case for a jury to determine whether USAA proved by a preponderance of the evidence that the unpaid loss was caused by an excluded storm surge. The trial court did not err, however, in directing a verdict for USAA as to the Hoovers’ claims for mental anguish, emotional distress, and punitive damages. View "Hoover v. United Services Automobile Association" on Justia Law