Justia Mississippi Supreme Court Opinion Summaries

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David Archie contested the results of the Hinds County Supervisor primary runoff election held on August 8, 2023, alleging election irregularities. He filed a petition for judicial review on September 8, 2023, one day past the statutory deadline. The key issue on appeal was whether the Hinds County Circuit Clerk’s office was open or closed on September 7, 2023, as the deadline would be extended if the office was closed.The Hinds County Circuit Court dismissed Archie’s petition, finding it was filed outside the allowable time period. The court based its decision on the fact that the courthouse was open on September 7, 2023, but did not make specific findings about whether the clerk’s office was open or closed.The Supreme Court of Mississippi reviewed the case and found that the evidence was insufficient to determine whether the clerk’s office was open or closed on September 7, 2023. The court noted that while the courthouse was open, the clerk’s office doors were locked, and there was conflicting evidence about whether the office was accessible for conducting business. The court vacated the circuit court’s judgment and remanded the case for a more thorough evidentiary hearing to determine the status of the clerk’s office on the critical date.The main holding by the Supreme Court of Mississippi was that the circuit court’s judgment was vacated and the case was remanded for further proceedings to establish whether the clerk’s office was open or closed on September 7, 2023, which would affect the timeliness of Archie’s petition. View "Archie v. Smith" on Justia Law

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In 1998, Michael Johnson, then 17, conspired with Aaron Johnson to murder Aaron’s roommate, Dustin Sean Parker. They planned the murder for hours, eventually deciding to bludgeon Parker to death with a metal barbell. After killing Parker, they wrapped his body in plastic bags and buried it in the woods. Johnson later bragged about the murder, leading to his arrest and conviction for deliberate-design murder. He was sentenced to life in prison without the possibility of parole.The Rankin County Circuit Court initially sentenced Johnson to life without parole. Following the U.S. Supreme Court's decision in Miller v. Alabama, which deemed mandatory life-without-parole sentences for juveniles unconstitutional, Johnson sought post-conviction relief. The trial court vacated his sentence and held a new hearing, considering the Miller factors. Despite this, the court reinstated Johnson’s life sentence, ruling that the parole statute's application was not unconstitutional.The Supreme Court of Mississippi reviewed the case. Johnson argued that the trial court misapplied the law and facts and that Mississippi Code Section 99-19-101 required jury sentencing for juveniles. The court found that recent statutory amendments did not entitle Johnson to jury sentencing, as he was convicted before July 1, 2024. The court also upheld the trial court's application of the Miller factors, noting Johnson’s age, the premeditated nature of the crime, and the lack of evidence suggesting his immaturity or inability to understand the consequences of his actions. The court affirmed the trial court’s decision, maintaining Johnson’s life sentence without parole. View "Johnson v. State" on Justia Law

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Derrick Chatman was convicted of two counts of sexual battery by a jury in the Adams County Circuit Court. The jury was also instructed on the lesser-included offense of gratification of lust for both counts. Chatman appealed, arguing that the jury’s verdict was ambiguous and not fully responsive to the verdict forms, which included the lesser-included offense. He claimed the trial court erred by not directing the jury to retire for further deliberations.The Adams County Circuit Court sentenced Chatman to thirty years for each count, with fifteen years suspended and fifteen years to serve consecutively. Chatman filed a motion for judgment notwithstanding the verdict or, alternatively, for a new trial, which the trial court denied. On appeal, Chatman raised the issue of the ambiguous verdict for the first time, arguing that the trial court should have directed the jury to deliberate further under Mississippi Rule of Criminal Procedure 24.3.The Supreme Court of Mississippi reviewed the case and agreed that the jury’s verdict was ambiguous regarding the sexual battery charges. The court found that the trial court should have directed the jury to retire for further deliberations. The court noted that the jury’s general verdicts of guilty did not clarify whether they found Chatman guilty of sexual battery or the lesser-included offense of gratification of lust. Consequently, the court reversed Chatman’s convictions for sexual battery.The Supreme Court of Mississippi reversed and remanded the case for either a new trial on the sexual battery charges or for resentencing on two counts of gratification of lust, at the option of the State. The court emphasized that the ambiguity in the jury’s verdict required this remedy to ensure a fair and just outcome. View "Chatman v. State of Mississippi" on Justia Law

Posted in: Criminal Law
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Soweto Ronnell Love pled guilty to two counts of attempting to acquire or obtain possession of a controlled substance by forged prescription and was sentenced as a habitual offender to five years on each count, to run consecutively. Love later filed a pro se Motion for Post-Conviction Collateral Relief (PCR), challenging the voluntariness of his guilty plea. The Tate County Circuit Court dismissed his PCR motion without an evidentiary hearing, finding that Love's plea was voluntary based on the record.On appeal, the Mississippi Court of Appeals affirmed the circuit court's dismissal of Love's PCR motion in a divided decision. The Court of Appeals held that a factual basis existed for Love's plea and that he failed to show his plea was involuntary. Love then filed a pro se motion for rehearing, which was denied, and subsequently filed a petition for writ of certiorari, which the Supreme Court of Mississippi granted.The Supreme Court of Mississippi found that the circuit court erred in dismissing Love's PCR motion without an evidentiary hearing. The court held that Love was misinformed about the minimum penalty he faced as a habitual offender, which amounted to a misapplication of the law and plain error. The court also found that the record did not confirm that Love knowingly pled guilty as a habitual offender. Consequently, the Supreme Court reversed the circuit court's dismissal of Love's PCR motion and the Court of Appeals' decision, remanding the case to the circuit court for an evidentiary hearing to determine whether Love voluntarily pled guilty as a habitual offender. View "Love v. State of Mississippi" on Justia Law

Posted in: Criminal Law
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A natural mother filed a petition to set aside the adoption of her child, D.A.P., more than five years after the final adoption decree. She claimed that the adoption was based on fraudulent misrepresentations that it would be an "open" adoption, allowing her continued contact with the child. The adoption was finalized on July 6, 2017, and the mother alleged that she was misled into believing she would maintain contact with her child post-adoption.The Neshoba County Chancery Court denied the mother's request for access to adoption records in 2021, citing the statute of limitations and lack of good cause. In 2022, the mother filed a petition to set aside the adoption decree, claiming fraud, coercion, and misrepresentation. The court dismissed her petition, noting that the mother had not appealed the original adoption judgment and that setting aside the adoption would prejudice the adoptive parents and the child. The court found no evidence of fraud upon the court, as the adoption petition clearly stated the termination of the mother's parental rights.The Supreme Court of Mississippi reviewed the case and affirmed the chancery court's decision. The court held that the mother's petition was untimely, as it was filed more than six months after the adoption decree, which is the statutory limit for challenging an adoption in Mississippi. The court also found no fraud upon the court, as there was no sworn testimony or filing indicating an open adoption. The court emphasized the importance of finality in adoption proceedings to ensure stability and security for the child. View "In the Matter of the Adoption of D.A.S." on Justia Law

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Patricia Wright was employed by the Public Service Commission of Yazoo City (PSC) from August 2014 until November 2018, when she was terminated for allegedly falsifying documentation regarding reconnecting a customer for non-payment. Wright appealed her termination to the PSC Board, which upheld the decision. Subsequently, Wright filed a lawsuit against the PSC and its general manager, Richie Moore, claiming her termination was in retaliation for refusing to participate in illegal activities. She sought lost wages, benefits, compensatory damages, punitive damages, and costs.The Yazoo County Circuit Court denied the PSC's motion for summary judgment, finding that there was a genuine issue of material fact regarding the reason for Wright's termination. The trial judge noted that the question of whether Wright understood what falsifying documents entailed and whether she was asked to do so was a matter for the jury to decide. The PSC then filed a petition for interlocutory appeal, arguing that Wright failed to identify any illegal activity by her supervisor that could lead to criminal penalties.The Supreme Court of Mississippi reviewed the case and reversed the trial court's denial of summary judgment. The Court held that Wright failed to provide sufficient evidence that her supervisor's actions constituted illegal activities warranting criminal penalties. Wright's deposition revealed that she did not refuse to participate in any specific illegal act as required under the public policy exception to the employment at will doctrine. Consequently, the Court rendered judgment in favor of the PSC, concluding that Wright did not meet her burden of showing a genuine issue of material fact regarding her wrongful termination claim. View "Public Service Commission of Yazoo City v. Wright" on Justia Law

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Ricardo Jones sued the City of Jackson for injuries sustained from driving into a pothole. Before filing the lawsuit, Jones sent certified letters to the mayor and city council members but did not send a notice of claim to the city clerk, as required by the Mississippi Tort Claims Act (MTCA).The Hinds County Circuit Court denied the City’s motion for summary judgment, which sought dismissal of Jones’s claims due to his failure to comply with the MTCA’s presuit notice requirement. The City then petitioned the Supreme Court of Mississippi for an interlocutory appeal.The Supreme Court of Mississippi reviewed the case de novo and found that Jones did not comply with the mandatory requirement to serve notice on the city clerk. The court held that the MTCA’s presuit notice requirement is clear and mandatory, and serving notice on the mayor or city council members does not suffice. Consequently, the court reversed the trial court’s decision and rendered judgment in favor of the City, dismissing all of Jones’s claims. View "The City of Jackson, Mississippi v. Jones" on Justia Law

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Jatavis Williams was indicted for first-degree murder after the shooting death of Tacari Walker. On November 9, 2020, police responded to a shooting in Columbus, Mississippi, where they found Walker unresponsive. Witnesses indicated that Williams and Walker had been arguing prior to the incident. Williams turned himself in the next day. At trial, Williams claimed self-defense, stating that Walker had threatened him and approached his vehicle aggressively. However, an eyewitness testified that Walker was unarmed and appeared happy before the shooting.The Lowndes County Circuit Court conducted a jury trial from August 22 to August 26, 2022. The jury found Williams guilty of first-degree murder, and he was sentenced to life imprisonment. Williams filed a motion for judgment notwithstanding the verdict or a new trial, which the trial court denied. He then appealed, arguing that the conviction was against the overwhelming weight of the evidence and that the trial court erred in denying his request for a mistrial due to disruptions during the trial.The Supreme Court of Mississippi reviewed the case and affirmed the lower court's decision. The court held that the trial court did not abuse its discretion in denying the mistrial. The disruptions, including an outburst from the victim’s mother and an inappropriate video during a witness's Zoom testimony, were addressed by polling the jury, who indicated they could remain impartial. The court also found that the jury's verdict was not against the overwhelming weight of the evidence, as the jury had properly considered the self-defense claim and found it unconvincing. Therefore, the conviction and sentence were upheld. View "Williams v. State of Mississippi" on Justia Law

Posted in: Criminal Law
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On March 7, 2018, a ninth grader named Becky was kidnapped at gunpoint by Jimmy David Williams, a friend of her stepfather, while she was on her way to school. Williams forced Becky into his vehicle, drove to a secluded area, and sexually assaulted her. After the assault, Williams dropped Becky off at school, where she immediately reported the incident to her JROTC instructor. Becky was taken to a hospital for a sexual assault examination, which revealed physical evidence consistent with her account. DNA evidence linked Williams to the crime.The Jackson County Circuit Court convicted Williams of sexual battery and sentenced him to thirty years in prison without the possibility of parole. Williams filed a motion for a new trial or a judgment notwithstanding the verdict, arguing that the conviction was against the overwhelming weight of the evidence due to conflicting testimony. The trial court denied his motion, leading to Williams's appeal.The Supreme Court of Mississippi reviewed the case and upheld the trial court's decision. The court found that the jury had appropriately resolved the conflicting testimonies, including a statement from a social worker suggesting Becky had been gang-raped by multiple men, which Becky denied. The court emphasized that the jury's role is to assess the credibility of witnesses and weigh the evidence. Given the substantial evidence supporting the conviction, including immediate reports by Becky and corroborating DNA evidence, the court concluded that the verdict was not against the overwhelming weight of the evidence. Therefore, the trial court did not abuse its discretion in denying Williams's motion for a new trial. The Supreme Court of Mississippi affirmed Williams's conviction and sentence. View "Williams v. State of Mississippi" on Justia Law

Posted in: Criminal Law
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In 2023, Christopher Sheely was convicted for possessing more than one-tenth gram but less than two grams of methamphetamine. He was sentenced to two years in the custody of the Mississippi Department of Corrections, with the remainder suspended for post-release supervision upon completing a drug and alcohol program. Sheely appealed, arguing that the trial court erred by denying his proposed broken chain of custody jury instruction and that the evidence was insufficient to support the jury’s verdict.The Forrest County Circuit Court initially handled the case, where Sheely was found guilty by a jury. Sheely moved for a directed verdict and later for a judgment notwithstanding the verdict or a new trial, both of which were denied by the trial judge. The trial court found that an adequate chain of custody had been established and that Sheely failed to produce evidence of tampering or substitution of the evidence.The Supreme Court of Mississippi reviewed the case. The court held that the evidence was sufficient to support the jury’s verdict that Sheely knowingly possessed a felony amount of methamphetamine. The court found that the jury was presented with enough evidence to conclude that Sheely was aware of the presence and character of the methamphetamine and that it weighed more than one-tenth of a gram. Additionally, the court held that the trial court did not abuse its discretion in refusing Sheely’s proposed chain of custody jury instruction, as Sheely failed to present evidence of probable tampering or substitution. The Supreme Court of Mississippi affirmed the lower court’s decision. View "Sheely v. State of Mississippi" on Justia Law

Posted in: Criminal Law