Justia Criminal Law Opinion Summaries

Donald Mitchell directly appealed his conviction for possession of cocaine with the intent to distribute and his habitual-offender sentence to the Supreme Court. Finding that the trial court erred by admitting evidence of Mitchell's prior convictions for possession of marijuana and cocaine, the Court reversed Mitchell's conviction, vacated his sentence, and remanded for a new trial. View "Mitchell v. Mississippi" on Justia Law

Dante Lamar Evans was convicted of the murder of his father and sentenced as an adult to a mandatory term of life imprisonment. Evans petitioned the Supreme Court for a writ of certiorari, raising six issues: (1) whether the trial court erroneously refused to permit the jury to consider Evans's theory of imperfect self-defense; (2) whether the trial court erred in excluding testimony concerning Darold Evans's alleged abuse of Evans and his mother; (3) whether the trial court erred in refusing funds to hire a post-traumatic stress-disorder (PTSD) expert; (4) whether the trial court improperly prohibited the jury from considering Evans's age in its deliberations; (5) whether the trial court erred in admitting Evans's statements made to security guards and law-enforcement officers; and (6) whether Evans's life sentence was unconstitutional. Upon review, the Supreme Court found find that Evans demonstrated an actual need for an expert on PTSD. Therefore, the trial court abused its discretion in denying funds to hire such an expert. The Court reversed the judgment of both the Court of Appeals and the trial court and remanded for a new trial. View "Evans v. Mississippi" on Justia Law

Marcus O'Neal Flowers a/k/a Tupac a/k/a Marcus Flowers was convicted of murder for fatally shooting Charles Wash. He claimed on appeal that the jury's verdict was against the overwhelming weight of the evidence and asked the Supreme Court for a new trial. He believed he was entitled to such relief because there were conflicts between the State's evidence and his evidence, and the credibility of the State's main witness was called into question. The Supreme Court affirmed, finding Flowers's arguments were without merit. View "Flowers v. Mississippi" on Justia Law

Defendant Steve Antonio Anthony was convicted in circuit court for selling cocaine. He appealed his conviction, arguing that: (1) the circuit court erred by excluding evidence on cross-examination of the prior felony charges of the State's confidential informant; (2) the circuit court erred in denying two peremptory challenges raised by the defense; and (3) the jury's verdict was against the overwhelming weight of the evidence. The Court of Appeals affirmed the conviction. Defendant raised the same issues in his appeal to the Supreme Court which found that the trial court erred by limiting the cross-examination of the confidential informant. Accordingly the Court reversed Defendant's conviction and remanded the case for a new trial. View "Anthony v. Mississippi" on Justia Law

Robert Lee Jenkins was convicted for possession of a controlled substance. He was sentenced to life imprisonment under the habitual-offender statute. The Supreme Court granted Jenkins's petition for writ of certiorari to examine whether the trial court erred by allowing a laboratory supervisor to testify regarding the results of substance testing, where the supervisor reviewed and verified the results, but another analyst actually performed the tests. Finding no error, the Court affirmed. View "Jenkins v. Mississippi" on Justia Law

Frederick Denell Grim was convicted by jury for the sale of cocaine. The circuit court adjudicated Grim a habitual offender and sentenced him to life imprisonment without the possibility of parole. The Court of Appeals affirmed the trial court's judgment of conviction and sentence. The Supreme Court granted Grim's petition for writ of certiorari to examine whether the trial court erred by allowing a laboratory supervisor, who neither observed nor participated in the testing of the substance, to testify in place of the analyst who had performed the testing. Finding no error, the Court affirmed. View "Grim v. Mississippi" on Justia Law

Pro se prisoner Edgar Earl Patton appealed his convictions on false pretense and fraudulent use of identity. He argued: (1) the circuit court judge engaged in improper ex parte communications; (2) he was denied his Sixth-Amendment right to counsel at all critical phases; (3) the circuit court erred in denying his motion to recuse the trial judge; (4) the circuit court erred by allowing a substantive amendment to the indictment; (5) he was denied the right to compulsory service of process; (6) Patton’s Fourth-Amendment protection against unlawful search and seizure was violated; (7) the circuit court erred by violating Uniform Circuit and County Court Rule 1.11; (8) the circuit court judge’s inquiry into Patton’s educational background for purposes of determining his ability to represent himself was an improper discovery tool that benefitted the State and violated his Fifth-Amendment right against self-incrimination; (9) the circuit court erred by denying Patton’s motion for directed verdict; (10) jurisdiction was improper and venue was not established; (11) the jury was improperly instructed; and (12) the indictment was legally insufficient and defective. Finding no reversible error, the Supreme Court affirmed Patton’s convictions and sentences. View "Patton v. Mississippi" on Justia Law

Howard Goodin appealed a circuit court's denial of his application for post-conviction relief. The circuit court denied Goodin’s claims that he was mentally retarded and that he had received ineffective assistance of counsel on the issues of mental illness and competency. After review of the record and pertinent authorities, the Supreme Court found that the circuit court erred in determining that Goodin was not mentally retarded. The Court also found that Goodin failed to prove ineffective assistance of counsel regarding competency at the conviction stage. Because these issues were dispositive, the Court did not address Goodin’s claim of ineffective assistance of counsel on the issue of mental illness. The circuit court's judgment was affirmed in part and reversed in part. Goodin's death sentence was vacated and this case was remanded to the Circuit Court of Newton County for resentencing on the capital murder charge. View "Goodin v. Mississippi" on Justia Law

The issue on direct appeal to the Supreme Court in this case involved Quincy Clayton's conviction for the murder of his wife Alice. The Court found the trial court erred in depriving Clayton submission of an alternative theory of defense, when his requested jury instruction on heat-of-passion excusable homicide was refused. Accordingly, the Court reversed and remanded this case to the Jones County Circuit Court for a new trial. View "Clayton v. Mississippi" on Justia Law

A Harrison County grand jury indicted Mark Kee Brown for felony escape, and as a habitual offender under Mississippi Code Section 99-19-81. The State later moved the trial court to amend the grand jury’s indictment to charge Brown as a habitual offender under Section 99-19-83 – a statute that requires a life sentence for defendants with two previous felony convictions, one of which was a “crime of violence.” The trial judge held that a prior conviction for burglary satisfied the violent-crime requirement for habitual-offender status, even though the State had produced no evidence that the burglary involved violence. Brown appealed. Because burglary is not a crime against the person, and not, as the Court of Appeals held, a per se crime of violence, the Supreme Court reversed the lower courts and remanded this case for further proceedings. View " Brown v. Mississippi" on Justia Law