Justia Mississippi Supreme Court Opinion Summaries

In this criminal case heard by the Supreme Court of Mississippi, Willie Douglas was convicted and sentenced to life imprisonment as a habitual offender for two counts of sale of less than two grams of cocaine. The cocaine was sold to a confidential informant, Ronald Keen, during two controlled purchases that were orchestrated and monitored by law enforcement officers from the Batesville Police Department. The substances bought during these controlled purchases were tested and confirmed to be cocaine by the Mississippi Forensics Laboratory.On appeal, Douglas raised multiple issues, including an illegal sentence, improper indictment, denial of the right to self-representation, bias of the trial judge, and credibility of witnesses, among others. The Supreme Court of Mississippi found all his claims to be without merit. It held that there was no violation of Douglas's constitutional rights and the evidence presented at trial was sufficient to uphold the jury's verdict. The court affirmed the conviction and life sentence. View "Douglas v. State of Mississippi" on Justia Law

This case involves a dispute between a group of individuals and companies associated with John Logan and a mix of investors and former investors in medical clinics that Logan has run. The parties attended a mediation to resolve five separate but related lawsuits. Following the mediation, RedMed believed there was an enforceable settlement agreement, while Logan believed the mediation only created a framework for further negotiations. The trial court granted RedMed’s Motion to Enforce Settlement, finding that a binding settlement agreement had been reached. Logan appealed, arguing that the trial court erred in finding a binding settlement agreement. The Supreme Court of Mississippi reverses the trial court's ruling. The court found that the proposed settlement agreement lacked material terms required by Mississippi contract law, such as the interest rate and term of a promissory note, and therefore no meeting of the minds occurred. The court further found that the conduct of the attorneys and mediator at the conclusion of the mediation indicated that mutual assent to the terms of a contract was lacking. As a result, the court concluded that no enforceable contract was formed at the mediation. Therefore, the case is remanded back to the trial court. View "Logan v. RedMed, LLC" on Justia Law

Timothy Robert Ronk, who was convicted of armed robbery and capital murder and sentenced to death, sought post-conviction relief for a second time. He claimed his post-conviction counsel was ineffective. The State of Mississippi, in response, requested an overruling of Grayson v. State, which held that ineffective-assistance-of-post-conviction-counsel claims are an exception to the bars in the Mississippi Uniform Post-Conviction Collateral Relief Act (UPCCRA). The Supreme Court of Mississippi agreed with the State, citing a recent decision (Howell v. State) which invalidated all cases in which Mississippi courts had applied a "judicially crafted fundamental-rights exception" to the UPCCRA’s bars. Therefore, the court partially overruled Grayson and denied Ronk's request for post-conviction relief. The court determined that Ronk's claims, including that his trial counsel failed to investigate his case thoroughly and that the State suppressed evidence, lacked arguable basis, were insufficient to overcome the statutory bars, and did not meet the "newly-discovered-evidence" exception. View "Ronk v. State of Mississippi" on Justia Law

In the case at hand, the Supreme Court of Mississippi dealt with an appeal by George Hawkins who was convicted for sexual battery of a minor under Mississippi Code Section 97-3-95(2). This law requires the State to prove that the defendant was in a position of trust or authority over the minor when the crime was committed. Hawkins' appeal was based on the argument that the State failed to present sufficient evidence of him being in such a position over the victim, as he had no legal authority over her.In 2014, Hawkins began dating Tonya Ingram and gradually became a part of her and her children’s lives, to the point where they even considered themselves to be common-law married. In the spring of 2015, Tonya and her children moved into Hawkins's home "as a family". Hawkins and Tonya filed their taxes jointly, claimed Tonya’s children as dependents, and contributed equally to the family’s finances. The victim, Jane, one of Tonya's children, trusted Hawkins, which ended when he sexually assaulted her one night.The court found that while Hawkins did not possess any legal authority over Jane, a reasonable jury could have concluded that he was in a position of trust or authority over her based on the totality of the circumstances and their relationship. The court held that the list of individuals who are typically in positions of authority provided in Section 97-3-95(2) serves only as examples, and does not limit this to persons in positions of legal authority over the child. Therefore, the court affirmed Hawkins' conviction. View "Hawkins v. State of Mississippi" on Justia Law

In this legal malpractice claim, Rachel Breal sued her former attorneys, the Downs Law Group and others, for allegedly negligent representation in a dismissed BP Deepwater Horizon oil-spill claim. The case was filed in the Circuit Court of the First Judicial District of Hinds County, Mississippi, but was then removed to the United States District Court for the Southern District of Mississippi by Downs Law. The case was later remanded back to the Hinds County Circuit Court. During a hearing, the trial court raised, on its own initiative, a forum-selection clause in Breal's retainer agreement with Downs Law, which stated that the proper forum and venue for any litigation relating to the agreement should be in the court of the 11th Judicial Circuit of Miami-Dade County. Based on this clause, the trial court dismissed the case for improper venue, and Breal appealed.The Supreme Court of Mississippi reversed the trial court's decision, holding that the trial court could not sua sponte enforce the forum-selection clause a year into the litigation. The court reasoned that improper venue could be waived if not timely raised, and therefore, the trial court could not enforce the forum-selection clause when Downs Law had failed to do so. The court found that Downs Law had waived any claim of improper venue by actively participating in the litigation in both federal and state courts in Mississippi without ever raising the issue of the forum-selection clause until prompted by the trial court. Therefore, the court concluded that the trial court erred by dismissing the case due to improper venue and remanded the case for further proceedings. View "Breal v. The Downs Law Group" on Justia Law

In a dispute before the Supreme Court of Mississippi, Amrut Patel claimed that Dilip Bhana failed to repay three loans. The Chancery Court of DeSoto County had granted a judgment in favor of Patel in 2014. In 2021, Patel attempted to renew the judgment by filing a notice of renewal with the DeSoto County Circuit Court. In 2022, Patel pursued executing the judgment in the DeSoto County Chancery Court. However, Bhana filed a motion to dismiss, arguing that the judgment had expired because Patel did not properly renew it. The chancery court denied Bhana’s motion to dismiss.Bhana's case was brought before the Supreme Court of Mississippi on interlocutory appeal. The Supreme Court clarified that there are three ways to renew a judgment in Mississippi: filing a notice of renewal with the clerk of the court that rendered the judgment, filing a motion to renew in the court that rendered the judgment, or filing a new suit on the judgment in any court in which venue is proper. The court found that Patel did not follow any of these methods properly. Patel had filed a notice of renewal in the circuit court, not the chancery court that had issued the judgment, and he had not filed a new suit to renew the judgment.The Supreme Court of Mississippi held that Patel's judgment against Bhana had expired because Patel had not renewed it in any manner provided by law or case precedent. The court also ruled that Bhana did not waive his statute of limitations defense and that the chancery court had abused its discretion by finding Bhana’s motion to dismiss untimely. Consequently, the court reversed the chancery court’s denial of Bhana’s motion to dismiss and rendered judgment in favor of Bhana. View "Dilip v. Patel" on Justia Law

In this criminal case, the Supreme Court of Mississippi upheld the conviction of the defendant, Adam Mills, for first-degree murder. The case stemmed from Mills brutally killing his girlfriend while allegedly under the influence of drugs. Mills appealed his conviction, arguing that he could not be convicted of first-degree murder because the evidence did not support a finding that he had the requisite mental capacity to form a premeditated intent to kill. Mills also contended that the trial court erred by admitting photographs and body camera footage from the crime scene.The Supreme Court held that the trial court did not abuse its discretion by admitting the photographs and body camera footage. It reasoned that the materials served a useful evidentiary purpose by providing the jury with visual evidence of the crime scene and the victim’s injuries, which could aid in determining Mills's intent. Regarding the defendant's argument about his mental capacity, the Court ruled that voluntary intoxication is not a defense to a specific-intent crime such as first-degree murder. The Court held that the extent and nature of the victim's injuries, inflicted by Mills, were indicative of a deliberate design to kill.Therefore, the Court affirmed Mills's conviction and life sentence for first-degree murder. View "Mills v. State of Mississippi" on Justia Law

In 2004, De’Andre Dampier was convicted of a capital murder committed during an auto-dealership robbery when he was 16 years old. He was sentenced to life in prison without parole, which was the only statutory sentence available at the time. In 2012, the United States Supreme Court ruled that imposing mandatory life-without-parole sentences on juveniles violates the Eighth Amendment. Based on this ruling, the Supreme Court of Mississippi granted Dampier’s request to seek post-conviction relief from his life-without-parole sentence. However, before the trial court addressed any of the factors from the US Supreme Court decision, it vacated Dampier’s life-without-parole sentence. Dampier then requested that a jury be convened to decide if he should be sentenced to life with or without parole, but the trial judge denied this request. After a hearing in which the trial judge considered the factors from the US Supreme Court decision, the judge reimposed a sentence of life in prison without parole.The Supreme Court of Mississippi affirmed the decisions of the lower courts, holding that Dampier did not have a statutory right to be sentenced by a jury. The court emphasized that the decision to be made by the trial court was whether Dampier was entitled to post-conviction relief from his life-without-parole sentence, imposed for a crime committed when he was a juvenile. The court also agreed with the lower courts that the trial judge did not err by denying Dampier’s request for jury sentencing. Furthermore, the court agreed with the lower courts that the trial court did not err by ruling that, after a careful consideration of the factors from the US Supreme Court decision, life without parole was an appropriate sentence for Dampier’s crime. View "Dampier v. State of Mississippi" on Justia Law

In the Supreme Court of Mississippi, Isaiah Gunn was convicted of first degree murder, attempted murder, aggravated assault, and shooting into a dwelling. He was sentenced to life, forty years, twenty years, and ten years respectively. Gunn contested his conviction on appeal, arguing that the jury was improperly instructed and that the State did not present sufficient evidence to support his convictions, as he believed he acted in self-defense. The Supreme Court of Mississippi affirmed Gunn’s convictions on all counts.Gunn was indicted for these charges following an incident at his ex-girlfriend's residence where he shot and killed her and attempted to kill another man present at the scene. Gunn argued that he acted in self-defense after his ex-girlfriend pointed a shotgun at him, but the jury rejected this argument. The court found that the jury had been properly instructed on the law relating to self-defense and deliberate design, and held that the verdict was not against the overwhelming weight of the evidence.In terms of the alleged improper jury instruction, the court noted that the instruction given allowed the jury to infer deliberate design to kill if they found that Gunn intentionally used a deadly weapon to kill the victim. The court found this instruction to be permissible, as it only allowed the jury to reach a conclusion if the presented evidence supported that conclusion. Furthermore, the court concluded that the verdict was not contrary to the overwhelming weight of the evidence, as the jury could have concluded from the evidence that Gunn was not in any imminent danger, but instead was the aggressor in the situation. View "Gunn v. Mississippi" on Justia Law

In Mississippi, Jackson Sales & Storage Co. (JSSC), a subsidiary of National Presto Industries, was granted an annual exemption from ad valorem property taxes by Hinds County for almost forty years. This exemption was based on a free-port-warehouse license issued to JSSC by the State Tax Commission in 1981. In 2019, however, Hinds County denied the exemption and assessed JSSC back taxes for 2012-18, arguing JSSC lacked the requisite free-port-warehouse license. JSSC sought relief in Hinds County Circuit Court, which held that JSSC’s license remained valid and in effect since 1981 and was not subject to renewal. The Circuit Court also ruled that JSSC owed no taxes for 2012-19. On appeal, the Supreme Court of Mississippi partially affirmed and partially reversed the lower court's ruling. The Supreme Court agreed that JSSC's license was valid since 1981 and that JSSC owed no taxes for 2012-18. However, the Supreme Court disagreed with the lower court’s finding that the license wasn’t subject to renewal and that JSSC owed no taxes for 2019. The Supreme Court held that the county could require JSSC to renew its license and that JSSC owes Hinds County the remaining $290,724.52 in ad valorem taxes for 2019. The court clarified that moving forward, the board of supervisors has discretion over whether it grants JSSC an exemption and over the period of time that exemption is in effect. View "Stokes v. Jackson Sales & Storage Co" on Justia Law