Justia Mississippi Supreme Court Opinion Summaries

Defendant Darrin Wilson appealed his conviction on rape, burglary extortion and two counts of kidnapping. On appeal, Defendant challenged the sufficiency of the evidence presented against him at trial, in addition to alleging procedural errors by the trial court. Upon review of the record, the Supreme Court found all of Defendant's arguments lacked merit, and affirmed the trial court's judgment. View "Wilson v. Mississippi" on Justia Law

Anthony Cuccia (Tony) separated from his wife, Julie Anne Cuccia after eleven years of marriage. At some point near the end of the marriage, Julie Anne began allowing rottweiler and pitbull dogs to live in the home. Tony disagreed with Julie Anne’s decision, resulting in a dispute that led to Tony filing for divorce. A few months later, Tony filed an amended complaint for divorce, adding that he was entitled to a divorce on the grounds of habitual cruel and inhumane treatment. Julie Anne filed an answer and counterclaim in which she denied being guilty of habitual cruel and inhumane treatment but admitted that irreconcilable differences existed, arguing in the alternative that she was entitled to a divorce on the grounds of habitual cruel and inhuman treatment. Tony and Julie Anne consented to an irreconcilable-differences divorce, but left equitable distribution of property, child custody, and alimony for the chancery court to decide. After a trial on September 21, 2009, the chancery court issued its final divorce decree and order, granting custody to Julie Anne, dividing the marital estate, and awarding alimony. Tony appealed the divorce decree due to the nature of the award given to Julie Anne regarding child custody, alimony, and equitable distribution of marital property. On appeal, the Court of Appeals overturned several of the chancery court’s findings and remanded the issues for reexamination. As a result, Julie Anne petitioned the Supreme Court for certiorari to review the findings of the Court of Appeals and the chancery court. Upon review, the Supreme Court affirmed the judgment of the Court of Appeals in part and reversed in part. On remand, the chancery court was instructed to determine the demarcation date for dividing the marital property, consider marital debt in that division, consider whether alimony was appropriate after making that division, reevaluate the custody matter, and craft an appropriate custody arrangement with the best interest of the children in mind. View "Cuccia v. Cuccia" on Justia Law

Defendant Ted Stone was convicted of the aggravated assault of Carolyn Stone for which he was sentenced to twenty years' incarceration and a $4,000 fine. He challenged the sufficiency of the evidence presented against him at trial. Finding no error, the Supreme Court affirmed Defendant's conviction and sentence. View "Stone v. Mississippi" on Justia Law

Isaiah Robinson attacked Respondent Linda Knox in a Kroger parking lot, punching her several times and taking her purse. Claiming that Kroger had a duty to place an armed guard in its parking lot and that its breach of that duty lead to her injuries, Respondent sued the Kroger Company and Kroger Limited Partnership and recovered damages. Kroger appealed. Upon review, the Supreme Court concluded that unless Kroger was on notice of an atmosphere of violence in its parking lot, it had no duty to place an armed guard there. Respondent failed to present sufficient evidence on that point, so the Supreme Court reversed the trial court's decision and remanded the case for entry of dismissal. View "The Kroger Co. v. Knox" on Justia Law

Business Communications, Inc. (BCI) asserted two breach-of-contract claims against its former employee, Albert Banks: breach of BCI's business-protection agreement (BPA), which included a noncompetition provision, and breach of BCI's reimbursement-of-costs agreement (RCA). At trial, the jury awarded BCI $1,000 for breach of the BPA and $9,000 for breach of the RCA. Thereafter, the Circuit Court of Madison County granted Banks’s motion for judgment notwithstanding the verdict (JNOV). Subsequently, the Mississippi Court of Appeals affirmed the circuit court's grant of JNOV as to the RCA, but reversed regarding the BPA, "reinstat[ing] the jury's verdict [of $1,000], and remand[ing the] case to the trial court to consider BCI's motion for attorney's fees." The Supreme Court granted Banks's petition for writ of certiorari to address the elements of a breach-of-contract claim involving a noncompete agreement and the nature of the damages to which BCI was entitled. Regarding the elements of a breach-of-contract claim, the Court held that monetary damages were a remedy for breach of contract, not an element of the claim. As to damages for breach of the BPA, BCI acknowledged it had sustained no identifiable loss. But because (1) the jury was instructed on both compensatory and nominal damages, (2) the special-verdict form did not specify the type of damages awarded, and (3) the jury's award of $1,000 was well within the continuum of legitimate nominal damage awards, the Court affirmed the Court of Appeals' reinstatement of that jury verdict. The Court also affirmed the Court of Appeals' decision to remand to the circuit court to consider BCI's motion for attorney's fees. View "Business Communications, Inc. v. Banks" on Justia Law

Defendant Rene Levario appealed the circuit court's denial of his motion to dismiss an indictment against him for felony Driving Under the Influence (DUI) Causing Death. In 2008, Defendant was involved in an automobile accident that resulted in the death of Gary Coulliette. At the scene, Defendant received five traffic tickets, one of them for DUI. Defendant posted a $25,000 bond for felony DUI Causing Death; he pled not guilty in justice court. His case was continued to October, 2008. Defendant again appeared, the charges against him were reduced to a misdemeanor, and that he pled guilty to the reduced charge. Defendant was convicted and ordered to pay a $300 fine and to attend Mississippi Alcohol Safety Education Program classes. In 2009, the State filed a "Motion to Set Aside Criminal Judgment" in justice court, arguing that the justice court had no jurisdiction to accept Defendant's plea on a charge of DUI Causing Death. After conducting a hearing on the issue, the justice court issued an order setting aside the conviction, found that Defendant had pled guilty to felony DUI Causing Death and that the felony charge had not been reduced to a misdemeanor. On October 13, 2009, the Jackson County Grand Jury returned an indictment charging Defendant with felony DUI Causing Death for the 2008 incident. On April 29, 2010, Defendant filed a Motion to Dismiss claiming double jeopardy. The circuit court overruled the motion, and Defendant appealed that decision. Upon review, the Supreme Court concluded that double jeopardy did not prohibit the State from indicting and prosecuting Defendant for felony DUI Causing Death in circuit court because the justice court did not have jurisdiction to convict him of the felony. Further, the Court concluded that the State did not violate Defendant's due-process rights in seeking to set aside his conviction in justice court and in prosecuting him in circuit court. Accordingly, the Court affirmed Defendant's conviction and sentence. View "Levario v. Mississippi" on Justia Law

A Madison County jury convicted Carla Hughes of two counts of capital murder. The jury declined to impose the death penalty, and the Circuit Court of Madison County imposed two sentences of life imprisonment without the possibility of parole, with both sentences to run concurrently. Hughes raised six issues on appeal: (1) whether the jury committed misconduct by submitting a note to the judge during deliberations asking whether the State could have called Hughes to the stand; (2) whether the verdicts were against the overwhelming weight of the evidence; (3) whether the trial court erred during jury selection when it denied one of Hughes's peremptory challenges; (4) whether the trial court erred in overruling Hughes's motion for a directed verdict; (5) whether the trial court erred by denying the motion to suppress the evidence found in Hughes's house; and (6) whether the trial court erred in admitting DNA evidence from a pair of shoes. Finding no error, the Supreme Court affirmed the circuit court's judgment. View "Hughes v. Mississippi" on Justia Law

At Anthony Lafayette's murder trial, when the jury informed the trial judge that it could not reach a unanimous verdict, the judge responded to the jurors that if they could not reach a verdict, he would call a new jury that would be "reasonable and fair" and that he hoped not to put the "County and State to the expense" if he could get around it. Lafayette moved for a mistrial, but the judge denied the motion, and Lafayette was convicted of manslaughter. On review, the Supreme Court found that the trial judge's instruction was inappropriate, and it "require[d]" that the Court reverse and remand the case for a new trial. View "Lafayette v. Mississippi" on Justia Law

The Mississippi State Department of Health (MDH) entered a final order disapproving the certificate of need application of Dialysis Solutions, LLC. Pursuant to Mississippi Code Section 41-7-201, Dialysis Solutions filed a direct appeal of the MDH's final order with the Supreme Court. Thereafter, the Court entered an order on its own motion, seeking briefing from the parties and the Attorney General regarding whether Section 41-7-201, as amended, was "constitutional under Mississippi Constitution article 6, section 146 and whether [the Supreme] Court [had] appellate jurisdiction over this direct appeal from a decision of the [MDH]." After due consideration, the Court concluded that Section 41-7-201, as amended, was unconstitutional under Article 6, Section 146 of the Mississippi Constitution. Accordingly, the Court refused to exercise appellate jurisdiction over Dialysis Solutions' direct appeal from the final order of the MDH. View "Dialysis Solutions, LLC v. Mississippi Dept. of Health" on Justia Law

David Anthony Jackson appeals his house-burglary conviction and twenty-five-year penitentiary sentence. The home of former United States Senator Trent Lott was burglarized in 2009 for which Jackson was indicted by a grand jury. On October 29, 2010, Jackson filed a Motion for Judgment Notwithstanding the Verdict, Or In The Alternative, For A New Trial. The circuit court denied this motion. Jackson filed this appeal, raising three assignments of error: (1) that the evidence was insufficient to sustain his conviction, specifically that the State failed to establish Jackson’s intent to commit the crime of larceny once inside the house; (2) that the trial court erred in refusing to give Jackson’s proffered jury instruction for the lesser-included offense of trespass; and (3) that the trial court erred in denying Jackson’s Motion for a Directed Verdict and his Motion for Judgment Notwithstanding the Verdict, or in the Alternative, for a New Trial. Finding no error, the Supreme Court affirmed Jackson's conviction and sentence. View "Jackson v. Mississippi" on Justia Law