Justia Mississippi Supreme Court Opinion Summaries

John Garon Saxton was convicted of aggravated assault for hitting his father-in-law, Toby Melton, in the head with a metal bat. The incident occurred after an altercation between Saxton and his mother-in-law, Vickie Melton, over Saxton disciplining his son. Saxton claimed he slapped Vickie after she pushed him near his injured shoulder, which Vickie denied. Vickie called Toby, but did not tell him about the slap. Saxton testified that he heard Vickie tell Toby about the slap over the phone. When Toby arrived, Saxton told him about the slap, and Toby reacted by pushing Saxton away. Saxton then retrieved a gun from his car, but did not point it at Toby. Saxton claimed that Toby then approached him again, prompting him to grab a bat and hit Toby.The trial court granted two jury instructions submitted by the State and denied a jury instruction submitted by the defense. Saxton appealed, arguing that the trial court erred in its decisions regarding the jury instructions.The Supreme Court of Mississippi affirmed the lower court's decision. The court found no reversible error with the trial court’s rulings on the jury instructions. The court held that while one of the State's instructions was an incomplete statement of Mississippi law, it did not result in a manifest miscarriage of justice, particularly given that Saxton was granted a self-defense instruction. The court also found no merit in Saxton's claim that the trial court erred by denying his proposed instruction, as the content of that instruction was covered elsewhere in the instructions. View "Saxton v. State" on Justia Law

Heather Walters, a Direct Support Professional at Brandi’s Hope Community Services, a long-term care facility for people with intellectual and developmental disabilities, noticed that a resident had been physically abused. She attempted to report the incident to her supervisors but received no response. Walters then took a photograph of the resident's injuries and shared it with a former coworker. After an internal investigation, Walters was fired for violating company policy and HIPAA regulations by taking and sharing the photograph. Walters filed a lawsuit against Brandi’s Hope and its CEO, Danny Cowart, for retaliatory discharge and malicious interference with employment.The County Court of Lee County found in favor of Walters, awarding her $100,000 in damages. The defendants appealed to the Lee County Circuit Court, which affirmed the lower court's decision. The defendants then appealed to the Court of Appeals, which reversed the lower courts' decisions, finding that the Mississippi Vulnerable Persons Act and the public policy exception established in McArn v. Allied Bruce-Terminix Co., Inc. were in conflict.The Supreme Court of Mississippi reversed the Court of Appeals' decision, finding no conflict between the Mississippi Vulnerable Persons Act and the public policy exception established in McArn. The court held that Walters was eligible to claim wrongful termination under McArn, as she was fired for reporting illegal activity. The court affirmed the jury's verdict that Brandi’s Hope terminated Walters because she reported the abuse. The case was remanded to the County Court of Lee County for further proceedings. The Court of Appeals' decision to render judgment in favor of Cowart on the malicious-interference-with-employment claim was not reviewed and thus stands. View "Brandi's Hope Community Services, LLC v. Walters" on Justia Law

In 2000, Antonio McDowell, a juvenile at the time, was convicted of capital murder and sentenced to life without parole. Following a 2012 Supreme Court ruling in Miller v. Alabama, which deemed mandatory life sentences without parole for juvenile defendants unconstitutional, McDowell's sentence was vacated. The trial court then proceeded with a jury trial for sentencing under Mississippi Code Section 99-19-101. The jury, after considering evidence related to the Miller criteria, was unable to agree on a sentence. The trial judge, instead of imposing a sentence of life, sentenced McDowell to life without parole, a decision that was affirmed by the Court of Appeals.The Mississippi Supreme Court, on certiorari review, found that the trial court's decision to proceed with a jury trial for sentencing under Section 99-19-101 made the section applicable to the entirety of the proceedings. This applicability continued when the jury failed to agree on a sentence. Therefore, the trial court erred by conducting the Miller analysis and sentencing McDowell to life without parole. The Supreme Court reversed the judgments of the Court of Appeals and the trial court and remanded the case back to the trial court for proceedings consistent with its opinion. View "McDowell v. State" on Justia Law

The case revolves around the dispute over whether the main roads within the Deerfield Estates subdivision in Newton County, Mississippi, are private or public. In 2001, the Newton County Board of Supervisors voted to accept the two main roads of the subdivision into the county road system. However, the roads were never added to the official county road registry. In 2020, the subdivision filed a complaint seeking a declaratory judgment that the roads are public and an injunction mandating the county to add them to the registry and perform repairs.The Newton County Chancery Court held that the roads had become public roads via express common law dedication and ordered that the roads be added to the county map and road register. The county appealed this decision, arguing that the subdivision's claims were barred by the doctrine of laches or the general three-year statute of limitations.The Supreme Court of Mississippi affirmed the lower court's decision. It held that the county's 2001 acceptance of the roads was effective and that the roads served public interest or convenience. The court also found that the county's failure to add the roads to the registry and the map in a timely manner did not negate the county's explicit acceptance of the dedication. Furthermore, the court ruled that the county could not invoke the doctrine of laches or the general three-year statute of limitations to bar the subdivision's request for a declaratory judgment that the roads are public roads. View "Newton County, Mississippi v. Deerfield Estates Subdivision Property Owners Association, LLC" on Justia Law

The case revolves around two Senate Bills—2780 and 3064—passed by the Mississippi Legislature in 2022. Senate Bill 2780 established the Independent Schools Infrastructure Grant Program (ISIGP), which allowed independent schools to apply for reimbursable grants for infrastructure projects funded by the Coronavirus State Fiscal Recovery Funds under the federal American Rescue Plan Act (ARPA). Senate Bill 3064 allocated $10 million from the Coronavirus State Fiscal Recovery Fund to ISIGP. Parents for Public Schools (PPS), a nonprofit organization advocating for public schools, filed a complaint alleging that ISIGP violated the Mississippi Constitution by appropriating public funds to private schools. PPS sought injunctive and declaratory relief, asserting associational standing on behalf of its members.The Chancery Court of Hinds County found that PPS had established associational standing. It also found that Senate Bills 2780 and 3064 violated the Mississippi Constitution by appropriating public funds to private schools. The court denied a motion to intervene by the Midsouth Association of Independent Schools (MAIS), which sought to challenge the constitutionality of the relevant section of the Mississippi Constitution under the First and Fourteenth Amendments.The Supreme Court of Mississippi, however, found that PPS lacked standing to bring the lawsuit. The court determined that PPS failed to demonstrate an adverse impact different from that of the general public. The court noted that the funds at issue were federal, not state, funds earmarked for specific infrastructure needs, and were not commingled with state funds. The court also found that PPS's challenge to general government spending was too attenuated to bestow standing. As a result, the court vacated the judgment of the Hinds County Chancery Court and rendered judgment dismissing PPS's complaint. View "Midsouth Association of Independent Schools v. Parents for Public Schools" on Justia Law

The case revolves around a custody dispute involving a minor child, J.B., born in March 2021. J.B. was placed in the custody of foster parents, John and Amy Caldwell, by the Mississippi Department of Child Protection Services (CPS) in June 2021. In October 2022, J.B.'s maternal great aunt, Wanda Hines, expressed interest in adopting J.B. Subsequently, the foster parents filed a petition for adoption in March 2023. In response, the relatives filed a motion to intervene and dismiss the adoption proceeding. CPS also filed a motion to dismiss, alleging that the foster parents violated their foster contract by pursuing an adoption action. The chancellor granted the relatives' motion to intervene and appointed a guardian ad litem to make a recommendation regarding the child’s best interest.The DeSoto County Chancery Court granted the foster parents durable legal and physical custody of J.B. in a temporary order until the final hearing on the merits of their adoption petition and dismissed CPS without a hearing. The relatives and CPS appealed this decision.The Supreme Court of Mississippi reversed the chancery court's decision, ruling that the chancellor erred by awarding permanent relief without a hearing. The court held that divesting and dismissing CPS from the case is permanent relief, which cannot be done without a hearing, even under the guise of a temporary order. The court also noted that durable legal custody is not an appropriate award after a termination of parental rights. The case was remanded for further proceedings. View "Hines v. Caldwell" on Justia Law

The case revolves around Gail Robinson, who was convicted of heat-of-passion manslaughter for the killing of Bobby Pruitt. The two had a tumultuous relationship, with both having been convicted of domestic violence against each other in the past. On the night of the incident, after a series of altercations, Robinson stabbed Pruitt, who later succumbed to his injuries. Robinson admitted to the stabbing, stating that she was the one who put the knife in Pruitt's chest, not her son who was also present at the scene.Prior to the Supreme Court of Mississippi, the case was heard in the Alcorn County Circuit Court. Robinson was charged with heat-of-passion manslaughter, and the jury was instructed on heat-of-passion manslaughter, self-defense, and reasonable use of force. Robinson was convicted as charged and sentenced to twenty years, with eight years suspended and twelve years to serve in the custody of the Mississippi Department of Corrections. Robinson's post-trial motion was denied by the trial court.In the Supreme Court of Mississippi, Robinson challenged her conviction on two grounds. First, she argued that her trial counsel was ineffective for failing to offer a jury instruction on her right to stand her ground in self-defense. Second, she contended that the State presented insufficient evidence to show she did not act in self-defense. The court affirmed her conviction, stating that the record was not clear enough to address her claim of ineffective assistance of counsel on direct appeal. The court also found that the State's evidence was sufficient to disprove Robinson's claim of self-defense. The court noted that Robinson continued to attack Pruitt past the point of any reasonable fear of imminent death or great bodily harm, and the jury had rejected her self-defense claim after weighing the evidence and credibility of the witnesses. View "Robinson v. State" on Justia Law

The case revolves around a contested municipal general election for the Ward 4 Alderman seat in Coldwater, Mississippi. Levon Hayes was declared the winner, but his opponent, Alice Thomas, filed an election contest, suspecting irregularities in the vote count. Hayes was served with the contest and a Rule 4 summons but did not respond or appear in court. Almost a year later, Thomas applied for a default judgment, which the Tate County Circuit Court granted, declaring Thomas the winner and ordering her immediate swearing in.The case was initially heard in the Tate County Circuit Court, where Thomas applied for a default judgment due to Hayes' failure to respond to the election contest. The court granted the default judgment, declared Thomas the winner, and ordered her immediate swearing in.The case was then brought to the Supreme Court of Mississippi. The court was tasked with determining whether a default judgment was permissible in this general election contest under Mississippi Code Section 23-15-951 and the Mississippi Rules of Civil Procedure. The court found that a default judgment was not permissible and that Thomas's failure to diligently prosecute her contest required its dismissal with prejudice. The court reversed the default judgment and remanded the case to the circuit court to dismiss Thomas's contest with prejudice and to reinstate Hayes as the elected candidate. The court also noted that the Rule 4 summons served to Hayes was improper and that Thomas's delays in prosecuting her contest violated the public's interest in having elections promptly decided. View "In Re: Contest of the Municipal General Election for the Ward 4 Alderman Seat" on Justia Law

The case involves Joshua Archie, who was convicted of conspiracy and capital murder. The incident occurred on October 26, 2012, when the Ridgeland Police Department responded to a "shots fired" call at Party City. Upon arrival, they found store manager Bobby Adams shot dead. The police were informed by store manager Regina Blake and store employee Undra Ward that a masked gunman with dreadlocks had entered the store, demanded money, and fled with the cash. The police suspected an inside job due to the nature of the crime. Ward later confessed to his involvement and implicated Archie as the gunman.In the lower courts, Archie was found guilty of both conspiracy and capital murder. He appealed the decision, arguing that the trial court erred by denying two of his requested jury instructions, that unauthenticated evidence was wrongfully presented to the jury, that the verdict is against the overwhelming weight of the evidence, and that his trial counsel was ineffective.The Supreme Court of Mississippi affirmed Archie’s conviction. The court found no error in the trial court's decisions, including the denial of Archie's requested jury instructions, the admission of an unauthenticated photograph of Archie, and the verdict's alignment with the weight of the evidence. The court also found that Archie's trial counsel was not ineffective. The court concluded that the evidence against Archie was overwhelming, and any errors in the trial process did not contribute to the verdict. View "Archie v. State" on Justia Law

This case involves a dispute over approximately one acre of coastal land in Mississippi. The disagreement is between John Aldrich and the State of Mississippi, with the main point of contention being whether the land in question is privately owned by Aldrich or is State-owned tideland. The dispute originated from a map published by the secretary of state in 1994, which marked the boundaries between private property and Public Trust Tidelands. According to the map, the land in question was designated as State-owned tideland. Aldrich disagreed with this designation and challenged the boundary in Harrison County Chancery Court in 1998. The State responded with a counterclaim, asserting that it held fee simple title to the property.After more than two decades of inactivity and extended litigation, the chancellor ruled in favor of Aldrich in 2022, vesting title in him and adjusting the tideland boundary. The chancellor made five consequential findings, all of which the State labeled as error on appeal. The most significant finding was that a 1784 Spanish land grant, which is the root of Aldrich’s title, negated the State’s claim to fee simple title. This finding called into question which lands passed from the federal government to Mississippi upon statehood.The Supreme Court of Mississippi affirmed the chancery court’s decision. The court found that the 1784 Spanish land grant was valid and vested title in Aldrich. The court also found that the State failed to meet its burden of proof that the artificial filling of the land was not done pursuant to a constitutional legislative enactment and for a higher public purpose. Therefore, the court concluded that the property belongs to Aldrich. View "State v. Aldrich" on Justia Law