Justia Criminal Law Opinion Summaries

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

In this criminal case heard before the Supreme Court of Mississippi, the appellant, Ronald Owens, was convicted by a jury for burglary of a business and was sentenced to serve seven years as a habitual offender. Following the guilty verdict, Owens moved for a Judgment Notwithstanding the Verdict (J.N.O.V.) or, alternatively, for a new trial; both motions were denied by the trial judge. Owens appealed the denial of a new trial, which was affirmed by the Court of Appeals. The Supreme Court of Mississippi granted Owens's petition for certiorari, focusing on the question of whether the trial judge abused his discretion by denying Owens's motion for a new trial.The case centered on a burglary that occurred at a closed pharmacy, with security footage showing an individual leaving the premises carrying a dark bag shortly after the pharmacy's alarm was triggered. A subsequent video from a nearby gas station showed Owens with a bag that matched the one seen in the first video. The prosecution also presented evidence of a stock bottle from the pharmacy found in Owens's home following his arrest.Owens argued that the state presented no evidence linking him to the burglary and that the bag he was seen carrying in the gas station video, which appeared to be red, could not be the same as the black bag seen in the video from the pharmacy. The Supreme Court of Mississippi affirmed the jury's verdict and the trial court's decision, arguing that the jury had enough evidence to rationally conclude that Owens was the individual involved in the burglary. The court held that the verdict was not contrary to the overwhelming weight of the evidence, and thus the trial judge did not abuse his discretion in denying Owens's motion for a new trial. View "Owens v. State of Mississippi" on Justia Law

In this case, Dwan Wakefield aided Byron McBride after McBride committed a car theft, kidnapping, and murder. Wakefield was convicted under Mississippi Code Section 97-1-5 for three counts of aiding McBride in the aforementioned crimes. He appealed to the Supreme Court of Mississippi, arguing that being charged multiple times for being an accessory after the fact for each felony committed by the principal violated the Fifth Amendment's protection against double jeopardy.The court found that, under the unit of prosecution test, the State may charge multiple violations of Section 97-1-5 for each felony committed. The court argued that each felony committed by the principal constitutes a separate unit of prosecution, allowing for multiple convictions under the statute. Wakefield's argument was based on the belief that he committed a single act (giving McBride a ride home) while McBride committed three distinct acts (auto theft, kidnapping, and murder). However, the court disagreed and upheld the judgments of the Court of Appeals and the Madison County Circuit Court.In conclusion, the court held that for the purposes of Mississippi’s accessory after the fact statute, Section 97-1-5, each felony committed by a principal offender constitutes a single unit of prosecution. Therefore, Wakefield was not put in jeopardy by being charged with three separate counts under Section 97-1-5. The court affirmed the lower court's decision. View "Wakefield v. State of Mississippi" on Justia Law

In this case, the Supreme Court of Mississippi affirmed the conviction and sentence of Timothy Marbley for aggravated domestic violence. The case originated from an incident in April 2020, where officers responded to a disturbance at an apartment complex. They found Sherita Lynch, Marbley's girlfriend, with injuries and a trail of blood leading from the apartment. Marbley was not present at the scene. Lynch and Marbley both testified at the trial, providing different accounts of the incident.The court noted that Marbley's counsel had filed a brief asserting that there were no arguable issues for review and complied with the procedures set out in Lindsey v. State when an attorney believes there are no appealable issues. Despite being given an opportunity, Marbley did not file a pro se brief. After reviewing the entire record, the court concurred with Marbley's counsel and found no issues that warranted appellate review.Consequently, the court affirmed Marbley's conviction for aggravated domestic violence and his sentence of ten years, five of which were suspended with nonreporting, supervised probation. View "Marbley v. State of Mississippi" on Justia Law

The case before the Supreme Court of Mississippi involves an appeal by Joe Exson, who was convicted of burglary of a dwelling, grand larceny, and first-degree arson. Exson was identified in a video committing these crimes, wearing a distinctive hoodie that was later found in his possession. He stole numerous items from the property and set it on fire, causing it to burn down entirely. The primary issue in Exson's appeal was the valuation of the stolen items, which was used to determine the charge of grand larceny. The property owner estimated the value of the stolen goods to be over $1,000, which is the minimum threshold for grand larceny under Mississippi law.Exson argued that the state failed to provide sufficient evidence of the fair market value of the stolen property and that the jury was improperly instructed on the value element of the larceny statute. However, the court noted that Exson failed to raise these arguments during his trial and thus, they were procedurally barred. Besides, the court found no merit in Exson's arguments as he was clearly seen committing the crime in the video. Moreover, reversing his larceny sentence would not substantially change his overall sentence since his arson sentence was longer and was to run concurrently.The court also examined the jury instructions and found that they tracked the language of the grand larceny statute correctly, even though they did not further define the element of value. Since Exson did not object to the instructions or request a definitional instruction during his trial, the court found no reversible error. Therefore, the Supreme Court of Mississippi affirmed Exson's convictions. View "Exson v. State of Mississippi" on Justia Law

In this case conducted by the Supreme Court of Mississippi, the defendant, Keith Montrago Jackson, was charged and convicted of sexual battery and sentenced to life imprisonment. The case stemmed from an incident involving Jackson and his girlfriend's twelve-year-old daughter, Anna. Jackson and Anna went to a store late at night, and upon their return, Jackson sexually assaulted Anna in his truck. Anna reported the incident to her school, and law enforcement was contacted.At trial, Anna testified about the incident and identified Jackson as the perpetrator. Forensic evidence, including sperm cells found in Anna that matched Jackson's DNA, was presented. Jackson testified in his own defense, denying the allegations. However, he was convicted and sentenced to life imprisonment.Jackson appealed the conviction, but his appellate counsel found no arguable issues for appellate review. The Court, having independently reviewed the record, also found no arguable issues. The Supreme Court of Mississippi affirmed the trial court's judgment. View "Keith Montrago Jackson a/k/a Keith Jackson v. State of Mississippi" on Justia Law

In this case, the Supreme Court of Mississippi reviewed the convictions and death sentences of Willie Cory Godbolt, who was found guilty of several counts of murder, kidnapping, attempted murder, and armed robbery. The Court addressed numerous issues raised by Godbolt, including whether the trial court erred by denying his motions to sever the charges, transfer the trial venue, limit voir dire, suppress certain evidence, and exclude victim impact testimony. Godbolt also claimed that his counsel provided ineffective assistance and that his death sentences were unconstitutional.The Court rejected all of Godbolt's claims, finding no error in the trial court's decisions or in the handling of his case. It affirmed Godbolt's convictions and sentences, holding among other things that the evidence supported the jury's findings of guilt and the imposition of the death penalty, the trial court properly admitted certain evidence, and Godbolt's counsel did not provide ineffective assistance. The Court also found that Godbolt's death sentences did not violate the constitution. View "Godbolt v. State of Mississippi" on Justia Law

The case at hand involves an appeal from Lady B. Garth against the Monroe County Circuit Court's dismissal of her appeal of a criminal misdemeanor conviction. The Supreme Court of Mississippi was tasked with determining whether the lower court erred in this dismissal.The pivotal issue revolved around the procedural aspects of perfecting an appeal from a justice court to a circuit court. According to Mississippi law, this requires a simultaneous filing of a written notice of appeal, a cost bond, and an appearance bond within 30 days of judgment. In this case, Garth failed to comply with these requirements. While she faxed a written notice of appeal on the 30th day following the original judgment, the cost bond and appearance bond were not submitted until six days later.The court concluded that Mississippi law does not permit the filing of the required bonds past the 30-day appeal time, and as such, the Monroe County Circuit Court committed no error in dismissing Garth's appeal. Therefore, the Supreme Court of Mississippi affirmed the lower court's decision.It should be noted that while Garth raised additional issues concerning the merits of the underlying justice-court judgment and alleged ineffective assistance of counsel, these were deemed outside the scope of the present appeal or more appropriately raised in post-conviction-relief petitions, and were thus not considered by the court in this decision. View "Garth v. State of Mississippi" on Justia Law

Percy Harris, a staff sergeant in the Mississippi Army National Guard, was convicted of first-degree murder of his wife, Shauna. Harris testified that during an argument, Shauna shot herself while he attempted to prevent her from doing so. However, Harris's stepson, M.K., testified that he heard his mother pleading with Harris not to shoot her. The prosecution pointed to several inconsistencies in Harris's account, such as the nature of Shauna's injuries and the fact that she was shot three times when Harris claimed to only hear two shots.On appeal, Harris argued that the prosecutor committed misconduct during her closing arguments, including making "send-a-message" and "golden-rule" arguments, commenting on his right to trial, and inflaming the jury's emotions. The Supreme Court of Mississippi disagreed, finding that the prosecutor's statements were not inflammatory and were within permissible bounds. The prosecutor's comments on Harris's credibility and demeanor were allowed because Harris chose to testify, hence putting his credibility and demeanor at issue. The Court affirmed Harris's conviction and life sentence. View "Harris v. State of Mississippi" on Justia Law

Jeremy Underwood was convicted of manslaughter in Mississippi for the stabbing death of Marcus Steele. Underwood appealed, claiming that the evidence was insufficient to prove beyond a reasonable doubt that he did not act in self-defense under the Castle Doctrine (which allows a person to use deadly force in certain situations when threatened in their own home), that the verdict was against the overwhelming weight of the evidence under the Castle Doctrine, and that the prosecution engaged in misconduct during opening and closing arguments. The Supreme Court of Mississippi affirmed the conviction, finding that the Castle Doctrine did not apply to this case and that the evidence was sufficient to support a manslaughter conviction. The court also found that the prosecutor's comments during opening and closing arguments did not constitute misconduct. Underwood had sold cocaine to Steele and Broach and claimed that Steele and Broach had forcibly entered his home multiple times before the stabbing occurred during an argument on Underwood's porch. However, the court found that the evidence did not support Underwood's claims that he was in imminent danger when he stabbed Steele. View "Underwood v. State of Mississippi" on Justia Law