Justia Mississippi Supreme Court Opinion Summaries

In this interlocutory appeal, the issue before the Supreme Court was whether the Circuit Court of Simpson County erred in ordering Defendants to produce a recorded statement and a privilege log of all documents withheld on the basis of privilege and relevance. Upon review of the matter, the Court found that the circuit court abused its discretion in ordering Defendants to produce the recorded statement without any analysis of their claim of work-product privilege. Additionally, the Court found that the circuit court erred by granting Plaintiff’s motion to compel discovery without conducting an item-by-item analysis of each objection. Therefore, the Court vacated the circuit court’s order and remanded the case for further proceedings. View "Powell v. McLain" on Justia Law

Pro se prisoner Edgar Earl Patton appealed his convictions on false pretense and fraudulent use of identity. He argued: (1) the circuit court judge engaged in improper ex parte communications; (2) he was denied his Sixth-Amendment right to counsel at all critical phases; (3) the circuit court erred in denying his motion to recuse the trial judge; (4) the circuit court erred by allowing a substantive amendment to the indictment; (5) he was denied the right to compulsory service of process; (6) Patton’s Fourth-Amendment protection against unlawful search and seizure was violated; (7) the circuit court erred by violating Uniform Circuit and County Court Rule 1.11; (8) the circuit court judge’s inquiry into Patton’s educational background for purposes of determining his ability to represent himself was an improper discovery tool that benefitted the State and violated his Fifth-Amendment right against self-incrimination; (9) the circuit court erred by denying Patton’s motion for directed verdict; (10) jurisdiction was improper and venue was not established; (11) the jury was improperly instructed; and (12) the indictment was legally insufficient and defective. Finding no reversible error, the Supreme Court affirmed Patton’s convictions and sentences. View "Patton v. Mississippi" on Justia Law

Howard Goodin appealed a circuit court's denial of his application for post-conviction relief. The circuit court denied Goodin’s claims that he was mentally retarded and that he had received ineffective assistance of counsel on the issues of mental illness and competency. After review of the record and pertinent authorities, the Supreme Court found that the circuit court erred in determining that Goodin was not mentally retarded. The Court also found that Goodin failed to prove ineffective assistance of counsel regarding competency at the conviction stage. Because these issues were dispositive, the Court did not address Goodin’s claim of ineffective assistance of counsel on the issue of mental illness. The circuit court's judgment was affirmed in part and reversed in part. Goodin's death sentence was vacated and this case was remanded to the Circuit Court of Newton County for resentencing on the capital murder charge. View "Goodin v. Mississippi" on Justia Law

The issue on direct appeal to the Supreme Court in this case involved Quincy Clayton's conviction for the murder of his wife Alice. The Court found the trial court erred in depriving Clayton submission of an alternative theory of defense, when his requested jury instruction on heat-of-passion excusable homicide was refused. Accordingly, the Court reversed and remanded this case to the Jones County Circuit Court for a new trial. View "Clayton v. Mississippi" on Justia Law

This appeal by Dorothy Knight arose from a 2011 circuit court order. In it, the circuit court affirmed an administrative decision by the Public Employees Retirement System (PERS) denying disability benefits. Upon review, a majority of the Supreme Court concluded that Knight met her burden, and that PERS' decision to deny her claim was not supported by substantial evidence. Accordingly, the Court reversed the appellate and circuit courts' rulings and remanded the case for further proceedings. View "Knight v. Public Employees' Retirement System of Mississippi" on Justia Law

A Harrison County grand jury indicted Mark Kee Brown for felony escape, and as a habitual offender under Mississippi Code Section 99-19-81. The State later moved the trial court to amend the grand jury’s indictment to charge Brown as a habitual offender under Section 99-19-83 – a statute that requires a life sentence for defendants with two previous felony convictions, one of which was a “crime of violence.” The trial judge held that a prior conviction for burglary satisfied the violent-crime requirement for habitual-offender status, even though the State had produced no evidence that the burglary involved violence. Brown appealed. Because burglary is not a crime against the person, and not, as the Court of Appeals held, a per se crime of violence, the Supreme Court reversed the lower courts and remanded this case for further proceedings. View " Brown v. Mississippi" on Justia Law

The Jackson County Court sitting as Youth Court exercised jurisdiction over two minors following allegations of abuse and neglect. The foster parents of the two minor children subsequently filed adoption proceedings in the Lincoln County Chancery Court. The Mississippi Department of Human Services ("MDHS") sought interlocutory appeal after unsuccessfully challenging the chancery court's jurisdiction to consider the adoption proceedings. Upon review, the Supreme Court found that the Chancery Court had jurisdiction over the adoption proceedings and affirmed the Chancery Court's judgment. View "Mississippi Dept. of Human Svcs. v. Watts" on Justia Law

In this interlocutory appeal, Ford Motor Company (Ford) wanted to preserve a confidential settlement agreement between it and the Estate and wrongful-death beneficiaries of Brian Cole (the Coles). The case on appeal was a separate action between the Coles, their attorneys, and among the attorneys themselves regarding expenses, a contingency-fee agreement, and a fee-sharing agreement. The chancellor denied Ford's motion and its "Notice of Intent to Seek Closure of Proceedings and Sealing of Documents." Before the Supreme Court, Ford raised three issues: (1) whether the settlement agreement was a public, judicial record or a private contract, which should be enforced; (2) whether the state's policy encouraging settlement agreements and the parties' interest in abiding by the terms of that agreement were sufficient grounds to protect the settlement from public scrutiny; and (3) whether there was any overriding public interest which would require disclosure of the terms of the settlement agreement. Upon review, the Supreme Court found that the settlement agreement was between private parties, did not involve issues of public concern, and was unnecessary to resolve the parties' disputes. Thus, the Court concluded that chancery court erred, in part, by denying Ford's motions. View "In the Matter of the Estate of Brian Cole" on Justia Law

Ahmad Butler was convicted of manslaughter by a jury for which he was sentenced to twenty years in the custody of the Mississippi Department of Corrections. Butler appealed, claiming that pretrial photo lineups were overly suggestive, that identifications were unreliable, and that the trial judge erred in denying his motion for a new trial. Finding that Butler's arguments were without merit, the Supreme Court affirmed the trial court's judgment of conviction and Butler's sentence. View "Butler v. Mississippi" on Justia Law

Michael Travis died in 1997 when a train struck his vehicle at a railroad crossing. His mother, Mary Travis, filed a wrongful-death suit against Illinois Central Railroad Company and its employees (collectively "Illinois Central") in Circuit Court. Trial was held in October 2009, and the jury assessed damages in the amount of $6.5 million. Based on the jury's allocation of fault, the trial court entered a judgment in favor of Travis in the amount of $4,875,000. Illinois Central filed this appeal. Upon review, the Supreme Court reversed and remanded the case for further proceedings, finding that the trial court erred in denying Illinois Central's motion for judgment notwithstanding the verdict, because the evidence did not support the jury’s verdict. View "Illinois Central Gulf Railroad Company v. Travis" on Justia Law