Justia Criminal Law Opinion Summaries

After a jury trial, Randy Pauley was convicted of malicious mischief and sentenced to five years in the custody of the Mississippi Department of Corrections (MDOC) and to pay a fine, restitution, and court costs. He appealed, arguing that: (1) the trial court erred in sustaining the State's hearsay objection; (2) the trial court's denial of a continuance constituted an abuse of discretion, or, alternatively, he received ineffective assistance of counsel; (3) the trial court erred in sustaining the State's relevance objections; (4) the trial court erred in sustaining the State's objection to his redirect examination of Alicia Littlefield; (5) the indictment was fatally defective; and (6) he was entitled to a jury instruction on insanity. Finding no error, the Supreme Court affirmed. View "Pauley v. Mississippi" on Justia Law

David McLymont was convicted of capital murder and conspiracy to commit robbery. He filed a motion for judgment notwithstanding the verdict, or in the alternative, for a new trial, which the trial court denied. McLymont appealed the trial court's denial to the Supreme Court claiming his conviction was contrary to the overwhelming weight of the evidence. McLymont contended the jury relied on the testimony of a biased witness and a tape recording obtained by that witness to reach its verdict. Upon review, the Supreme Court concluded that contention was meritless. The State presented evidence against McLymont in addition to the witness and the tape recording in question. Accordingly, the trial court did not err when it denied McLymont's post-trial motion. View "McLymont v. Mississippi" on Justia Law

Bobby Batiste was convicted of capital murder with the underlying felony of robbery for the slaying of his roommate, Andreas Galanis. After a sentencing hearing, the jury determined that Batiste should be sentenced to death. The Circuit Court denied Batiste's post-trial motions. Batiste appealed, raising fifteen assignments of error. After carefully reviewing the record and Batiste's arguments, the Supreme Court found no reversible error occurred and therefore affirmed Batiste's conviction and sentence. View "Batiste v. Mississippi" on Justia Law

Dondrego Bolton was charged with burglary of a dwelling in 2010. He was found guilty and sentenced to twenty years in prison. Bolton's indictment originally charged him with breaking and entering a dwelling with the intent to commit larceny. At trial, the jury was instructed on burglary of a dwelling and the lesser-included offense of trespassing. The jury was told that if it found that Bolton had broken and entered into the home "[w]ith the intent to commit the crime of larceny or any other crime," he was guilty of burglary. Bolton did not object to the jury instructions at the time. The Court of Appeals found these jury instructions to be sufficient. Upon review, the Supreme Court concluded that under its recent holding in "Daniels v. State," (107 So. 3d 961 (Miss. 2013)), the jury did have to find that Bolton had intended to commit larceny, since that was the intended offense specified by the grand jury. Here, however, the Court of Appeals found it sufficient that "[t]he jury found beyond a reasonable doubt that Bolton intended to commit a crime in Vance's house . . . ." Bolton argued on appeal to the Supreme Court that the jury instructions were improper because they permitted the jury to convict him of burglary if it found that he had intended to commit any crime while inside the dwelling. Because the jury was improperly instructed on the essential elements of burglary consistent with the Court's recent decision in "Daniels," the Court reversed the decisions of the Court of Appeals and the Circuit Court and remanded the case to the trial court for further proceedings. View "Bolton v. Mississippi" on Justia Law

Melvin Grayer was convicted of burglary and sentenced as a habitual offender to seven years without the possibility of parole or probation. Grayer appealed, claiming that he received ineffective assistance of counsel because his trial counsel failed to request a circumstantial-evidence jury instruction and that he was sentenced as a habitual offender without competent evidence of his prior felony convictions. Upon review, the Supreme Court affirmed Grayer's conviction and sentence of seven years, but vacated his habitual-offender sentence enhancement, because the State failed to prove Grayer was a habitual offender by competent evidence. View "Grayer v. Mississippi" on Justia Law

Blayde Grayson was indicted for capital murder while in the commission of burglary with the intent to steal personal property. A jury found him guilty of capital murder and, in a separate sentencing proceeding, sentenced him to death. The Supreme Court affirmed Grayson's conviction and death sentence. In early 2003, Grayson filed his first petition seeking post-conviction collateral relief (PCR). The Supreme Court denied relief. Grayson then filed his "Motion for Leave to File Successor Petition for Post-Conviction Relief" and "Motion for Access." Upon review, the Supreme Court concluded that PCR petitioners who have been sentenced to death do have a right to the effective assistance of PCR counsel. Grayson's counsel in his first PCR proceedings before the Supreme Court rendered deficient performance. However, Grayson failed to show that this deficient performance prejudiced him. Therefore, Grayson's claim that he received ineffective assistance of PCR counsel was deemed without merit. Furthermore, Grayson failed to show that his claims met any exceptions to the procedural bars, and his "Motion for Leave to File Successor Petition for Post-Conviction Relief" was dismissed as procedurally barred. Grayson was hereby granted leave to proceed in the circuit court with a motion for access. "As a matter of due process, Grayson should be allowed access to his experts, subject to the rules and regulations of the Mississippi Department of Corrections (MDOC). Because MDOC's rules and regulations presently require a court order, MDOC should be noticed with the request for access and afforded an opportunity to show cause why its present policies do not violate petitioner's due-process rights." View "Grayson v. Mississippi" on Justia Law

Travis Keithley was convicted for aggravated assault. On appeal, he argued that it was plain error to admit into evidence the "statements" of two anonymous people, that the verdict was not supported by the evidence, and that he received ineffective assistance of counsel. Finding no reversible error, the Supreme Court affirmed Keithley's conviction and sentence, and dismissed his ineffective-assistance-of-counsel claims without prejudice. View "Keithley v. Mississippi" on Justia Law

Twonia Renee Williams was convicted for the murder of Katrina Sergeant. She was sentenced to life imprisonment in the custody of the Mississippi Department of Corrections (MADOC). On appeal, Williams contended that jury instructions S-2A, S-4, and/or S-6 were given in error. Upon review, the Supreme Court concluded that the circuit court erred in granting instruction S-4, and such error could not be considered harmless in this case. Therefore, Williams's conviction and sentence were reversed and the case remanded for a new trial. View "Williams v. Mississippi" on Justia Law

The Supreme Court reversed the conviction and sentence in the first trial in this case in 2009, and remanded the case to the trial court, finding that the defendant, Tomarcus Fulks, had been entitled to a continuance based on the State's untimely disclosure of a key witness. In 2011, a jury reconvicted Fulks of armed robbery and acquitted him of aggravated assault. He received a sentence of thirty-five years in the custody of the Mississippi Department of Corrections (MDOC). On appeal, Fulks argued: (1) the trial court erred in allowing the State to introduce Fulks's prior testimony from his first trial; (2) the trial court erred in denying Fulks's motion for recusal; (3) the trial court erred in allowing the prosecutor to inform the jury that coindictee Joshua Glenn had entered a plea of guilty to a charge of aiding and abetting after the fact; and (4) the trial court erred when it allowed prior testimony of State's witness Sherry Franks, who was found to be "unavailable" for trial, into evidence. Finding no error, the Supreme Court affirmed. View "Fulks v. Mississippi" on Justia Law

David Parvin appealed his murder conviction, characterizing his arguments as "a 'Weathersby' case with a 'Daubert' twist." Parvin maintained that his wife's death was caused by accident, and the State's principal evidence refuting his defense at trial consisted of expert testimony, accompanied by a computer-generated reconstruction of the scene of her demise. The State argued that the experts' opinions about the physical evidence proved the victim was intentionally killed. Although the Supreme Court found no merit in Parvin's Weathersby claim, the Court agreed that certain expert testimony and the visual depiction of that testimony should not have been presented to the jury. Because this evidence severely prejudiced Parvin's defense, the Court reversed the conviction and remand the case to the Circuit Court for a new trial. View "Parvin v. Mississippi" on Justia Law