Justia Mississippi Supreme Court Opinion Summaries

When prosecutor Charles Graves was not prepared to proceed to trial and had not produced a video to defense counsel, a circuit court judge held him in criminal contempt and ordered him to be incarcerated. Upon review of the trial court record, the Supreme Court found that the trial judge denied the prosecutor due process of law and that the record contained insufficient evidence of criminal contempt. The Court reversed the prosecutor's convictions and the order of the circuit court was vacated.

Respondent Charles Gant possessed a letter of intent to purchase property. He offered to sell the property to Grant Legacy, LLP once he completed the purchase. Grand responded to the offer by agreeing to purchase the property through an unnamed partnership entity with Respondent to be formed at a later date. The new partnership was called "Grand Legacy of Mississippi, LP (Grand-MS). After the purchase, Grand and Grand-MS claimed that Respondent stated he would not profit from the purchase and resale. The two Grands argued that Respondent had a duty to disclose his intent to profit on the original property sale, and that in failing to disclose that information, Respondent committed fraud. The trial court concluded that the Grand-MS partnership agreement contained no clause prohibiting Respondent from making a profit on the land-purchase-transaction. The trial court granted summary judgment in favor of Respondent, finding he had no duty to disclose any profit made to the newly formed partnership. Upon review, the Supreme Court concluded that the essence of this case centered around the duties limited partners owe one another and the allegation of fraud stemming from an alleged breach of those duties. The Court found no basis by which it would disturb the trial court's findings. The Court affirmed the grant of summary judgment in favor of Respondent.

Since his conviction in 1979 for capital murder, Defendant Robert Jackson filed multiple unsuccessful motions and applications for post-conviction relief. Based on the Supreme Court's dispositions of his 2002, and 2004 applications, the circuit court summarily dismissed the application underlying this case, and the Court of Appeals affirmed. Undeterred, Defendant petitioned the Supreme Court arguing that his capital murder indictment was constitutionally insufficient. The Supreme Court granted Defendant's pro se petition for the writ of certiorari in this instance because the Court found that the trial court erroneously dismissed Defendant's PCR motions: "we recognize that the trial court dismissed the motion as a successive writ based on our 2002 and 2004 denials of [Defendant's] applications, and the Court of Appeals interpreted our denials as rejections of [Defendant's] arguments." the Court set aside its own decisions in 2002 and 2004, and reversed the trial court's dismissal and the Court of Appeals' decision. The Court remanded the case back to the trial court for further post-conviction-relief proceedings.

This case stems from an interlocutory appeal by Kelly Blossom regarding the issuance of a protective order by the Rankin County Chancery Court that denied her attempt to take two depositions in her divorce case. In 2009, Michael Blossom filed a complaint and obtained a temporary restraining order, preliminary injunction and permanent injunction against Ms. Blossom enjoining her from any contact with their children. At the time the trial court issued the protective order, Ms. Blossom was being prosecuted for sexual battery in the circuit court. One of the witnesses was the minor victim in the criminal case. In the criminal case, Ms. Blossom eventually pled guilty to having committed sexual battery. The other potential deponent, another minor, was identified by Ms. Blossom as having knowledge about the the sexual battery from the criminal case. Upon review of the trial court record, the Supreme Court found that the chancellor of the court below erred by granting the protective orders without meeting the requirements set out in the Mississippi Rules of Civil Procedure: "the fact that a witness is an 'alleged minor victim of a crime' alone does not constitute sufficient grounds to deny a party the right to depose that witness." Therefore, the Court reversed the decision of the lower court and remanded the case back to the trial court for further proceedings.

After John Sykes died in the emergency room at Calhoun Health Services, his estate sued the hospital for wrongful death, claiming that Mr. Sykes should have been hooked up to a cardiac monitor. Mr. Sykes was admitted after complaining of chest pains. He did not appear to be in distress, was not short of breath and was not sweating. He denied having any other symptoms. Mr. Sykes would later be diagnosed with "severe cardiomegaly" and died of "sudden cardiac death" related to "severe. . . hypertensive heart disease." The trial judge held that the estate failed to prove that the hospital had deviated from an applicable standard of care, and failed to prove that use of the cardiac monitor would have made a difference for Mr. Sykes' care. The Supreme Court found that all of the estate's issues concerned factual determinations that were within the discretion of the trial court. The Court affirmed the trial court's judgment.

In this wrongful death case, a prisoner escaped from the custody of the Hinds County sheriff. While evading capture, the prisoner struck a pedestrian with a stolen vehicle. The trial court denied the County's motion for summary judgment based on its claim of sovereign immunity, and the County appealed. Finding no right to appeal a pretrial denial of sovereign immunity, the Supreme Court dismissed this appeal, finding "no compelling reason to abandon our current practice regarding interlocutory review of pretrial denials of sovereign immunity."

Appellees Michael Howard and Shannon Poole were awarded a $4 million jury verdict against InTown Lessee Associates, LLC, an extended stay motel, for injuries they sustained as victims of an armed robbery in the motel. InTown appealed the verdict, challenging the trial court's denial of its motion for a directed verdict. Upon review of the trial record and the applicable legal authority, the Supreme Court could not conclude that the trial court abused its discretion in denying InTown's motion. Accordingly, the Court affirmed the trial court's decision and the jury verdict in favor of Appellees.

Defendant Virgil Johnson was convicted of aggravated assault and armed robbery by the circuit court. The Court of Appeals affirmed his conviction and sentence. On appeal, Defendant asserted that his right to a speedy trial was violated because 860 days passed between the time he was arrested and the date of his trial. Upon careful consideration of the trial court record and the applicable legal authority, the Supreme Court agreed with the appellate court, finding "no merit in [Defendant's] averment."

Responding to a 911 call in November 2008, police observed a male sitting in the driver's seat of a vehicle facing forward. The victim was suffering from a gunshot wound to the left side of his head, and did not appear to be breathing. Defendant Roy Page was tried for murder and sentenced to life in prison for the shooting. On appeal, Defendant challenged the sufficiency of the evidence against him. Upon careful consideration of the lengthy trial record and the applicable legal authority, the Supreme Court found that the evidence presented to the jury was sufficient to support Defendant's murder verdict. Furthermore, the overwhelming weight of the evidence also supported the verdict. Accordingly, the Court affirmed the judgment and sentence of the trial court.

Defendant Chad Booker was convicted of manslaughter and sentenced to twenty years' imprisonment. Defendant unsuccessfully appealed his sentence to the Court of Appeals. On appeal to the Supreme Court, Defendant argued multiple errors at the trial court entitled him to a new trial. The majority for the Court of Appeals found no merit in Defendant's arguments. Though it affirmed the appellate court's holding, the Supreme Court took the opportunity to expand upon points in the Court of Appeals' discussion on "Weathersby v. State" and whether the "Weathersby Rule" was correctly interpreted by the lower courts in Defendant's case. In sum, the rule applies where a defendant or his witnesses are the only eyewitnesses to the homicide: "Their version, if reasonable, must be accepted as true unless substantially contradicted in material particulars by a credible witness or witnesses for the state, or by the physical facts of the common knowledge." In Defendant's case, the Weathersby rule was inapplicable because Defendant's own version of the incident satisfied the elements of manslaughter. Furthermore, Defendant's version was substantially contradicted "in material particulars" by witnesses presented at trial. The Supreme Court found that the trial judge correctly found Weathersby inapplicable and properly permitted this case to go to the jury.