Justia Mississippi Supreme Court Opinion Summaries

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

Sweet Valley Missionary Baptist Church filed a complaint against its insurance carrier, Alfa Insurance Corporation. Based on Sweet Valley’s failure to cooperate in discovery, the trial court entered an order of dismissal. Sweet Valley then filed a motion to set aside judgment, or, in the alternative, a motion for new trial. The trial court denied the motion, and, in response, Sweet Valley filed a second complaint against Alfa the same day. The trial court dismissed the second claim based on the expiration of the statute of limitations. Sweet Valley appealed. On rehearing, the Court of Appeals reversed the trial court’s judgment and remanded for further proceedings. Alfa filed a petition for writ of certiorari, and the Supreme Court granted it. Upon review, the Supreme Court held that a motion filed pursuant to Mississippi Rule of Civil Procedure 59(e) tolls the applicable statute of limitations, and it reversed the decision of the trial court. View "Sweet Valley Missionary Baptist Church v. Alfa Insurance Corporation" on Justia Law

Every divorce based on irreconcilable differences in Mississippi must proceed under either Section 93-5-2(2) or Section 93-5-2(3), but not both. In this case, the two subsections were conflated and confused. As a result, the Supreme Court reversed the Chancery Court's judgment and remanded the case for further proceedings. View "Sanford v. Sanford" on Justia Law

Levi Jenkins was indicted and on two counts of sexual battery and one count of statutory rape against his then-five-year-old niece. He was convicted only of fondling, a lesser-included offense of the second count of sexual battery. Jenkins appealed, raising various issues. Finding his arguments to be without merit, the Supreme Court affirmed the Circuit Court's judgment. View "Jenkins v. Mississippi" on Justia Law

Psycamore, LLC, sought approval to operate a mental-health treatment facility in an area of Ocean Springs where the zoning ordinance allowed facilities for the examination and treatment of human patients. The City denied Psycamore’s application, but the circuit court reversed and the City appealed. Because the Supreme Court found that the City’s decision was arbitrary and capricious, it affirmed the circuit court’s ruling. View "City of Ocean Springs v. Psycamore, LLC" on Justia Law