Justia Criminal Law Opinion Summaries

A Pike County jury convicted James Richard Conners Jr. of two counts of murder and two counts of possession of a firearm by a felon. The circuit court imposed two life sentences for the murder convictions and two ten-year sentences for the possession-of-a-firearm-by-a-felon convictions, with all sentences to run consecutively. Conners appealed, arguing that the admission of two forensic reports at his trial violated his right of confrontation under the Sixth Amendment to the United States Constitution and constituted plain error. He also argued that he received ineffective assistance of counsel due to counsel's failure to make a Confrontation Clause objection to the admission of the forensic reports, and due to counsel's failure to object to gruesome photographs and evidence of Conners's past criminal activity and gang affiliation. Upon review, the Supreme Court found that the trial court erred by admitting the forensic test reports without live testimony from the analysts who performed the tests, but that the error was harmless. Furthermore, the Court found that Conners did not receive ineffective assistance of counsel, because he could not show that he was prejudiced by any deficient performance by counsel. Therefore, the Court affirmed his convictions and sentences.

Defendant Jeffrey Yeatman filed a motion for post-conviction relief in circuit court. The motion was denied, and Defendant appealed. The Court of Appeals affirmed. Defendant raised three issues on appeal to the Supreme Court: (1) whether Defendant's indictment was properly amended; (2) whether the Court of Appeals erred when it failed to address Defendant's argument that he was illegally sentenced as a habitual offender because it was not stated in his criminal information; and (3) whether Defendant's sentence was illegal because his fine exceeded the amount prescribed by statute. Upon review, the Supreme Court affirmed in part, reversed in part: the Court affirmed the amendment to the indictment, reversed the trial court's denial of Defendant's petition for post-conviction relief regarding his habitual-offender-status issue, and vacated Defendant's fine. The case was remanded to the circuit court for further proceedings.

Defendant Darrin Wilson appealed his conviction on rape, burglary extortion and two counts of kidnapping. On appeal, Defendant challenged the sufficiency of the evidence presented against him at trial, in addition to alleging procedural errors by the trial court. Upon review of the record, the Supreme Court found all of Defendant's arguments lacked merit, and affirmed the trial court's judgment.

Defendant Ted Stone was convicted of the aggravated assault of Carolyn Stone for which he was sentenced to twenty years' incarceration and a $4,000 fine. He challenged the sufficiency of the evidence presented against him at trial. Finding no error, the Supreme Court affirmed Defendant's conviction and sentence.

Defendant Rene Levario appealed the circuit court's denial of his motion to dismiss an indictment against him for felony Driving Under the Influence (DUI) Causing Death. In 2008, Defendant was involved in an automobile accident that resulted in the death of Gary Coulliette. At the scene, Defendant received five traffic tickets, one of them for DUI. Defendant posted a $25,000 bond for felony DUI Causing Death; he pled not guilty in justice court. His case was continued to October, 2008. Defendant again appeared, the charges against him were reduced to a misdemeanor, and that he pled guilty to the reduced charge. Defendant was convicted and ordered to pay a $300 fine and to attend Mississippi Alcohol Safety Education Program classes. In 2009, the State filed a "Motion to Set Aside Criminal Judgment" in justice court, arguing that the justice court had no jurisdiction to accept Defendant's plea on a charge of DUI Causing Death. After conducting a hearing on the issue, the justice court issued an order setting aside the conviction, found that Defendant had pled guilty to felony DUI Causing Death and that the felony charge had not been reduced to a misdemeanor. On October 13, 2009, the Jackson County Grand Jury returned an indictment charging Defendant with felony DUI Causing Death for the 2008 incident. On April 29, 2010, Defendant filed a Motion to Dismiss claiming double jeopardy. The circuit court overruled the motion, and Defendant appealed that decision. Upon review, the Supreme Court concluded that double jeopardy did not prohibit the State from indicting and prosecuting Defendant for felony DUI Causing Death in circuit court because the justice court did not have jurisdiction to convict him of the felony. Further, the Court concluded that the State did not violate Defendant's due-process rights in seeking to set aside his conviction in justice court and in prosecuting him in circuit court. Accordingly, the Court affirmed Defendant's conviction and sentence.

A Madison County jury convicted Carla Hughes of two counts of capital murder. The jury declined to impose the death penalty, and the Circuit Court of Madison County imposed two sentences of life imprisonment without the possibility of parole, with both sentences to run concurrently. Hughes raised six issues on appeal: (1) whether the jury committed misconduct by submitting a note to the judge during deliberations asking whether the State could have called Hughes to the stand; (2) whether the verdicts were against the overwhelming weight of the evidence; (3) whether the trial court erred during jury selection when it denied one of Hughes's peremptory challenges; (4) whether the trial court erred in overruling Hughes's motion for a directed verdict; (5) whether the trial court erred by denying the motion to suppress the evidence found in Hughes's house; and (6) whether the trial court erred in admitting DNA evidence from a pair of shoes. Finding no error, the Supreme Court affirmed the circuit court's judgment.

At Anthony Lafayette's murder trial, when the jury informed the trial judge that it could not reach a unanimous verdict, the judge responded to the jurors that if they could not reach a verdict, he would call a new jury that would be "reasonable and fair" and that he hoped not to put the "County and State to the expense" if he could get around it. Lafayette moved for a mistrial, but the judge denied the motion, and Lafayette was convicted of manslaughter. On review, the Supreme Court found that the trial judge's instruction was inappropriate, and it "require[d]" that the Court reverse and remand the case for a new trial.

David Anthony Jackson appeals his house-burglary conviction and twenty-five-year penitentiary sentence. The home of former United States Senator Trent Lott was burglarized in 2009 for which Jackson was indicted by a grand jury. On October 29, 2010, Jackson filed a Motion for Judgment Notwithstanding the Verdict, Or In The Alternative, For A New Trial. The circuit court denied this motion. Jackson filed this appeal, raising three assignments of error: (1) that the evidence was insufficient to sustain his conviction, specifically that the State failed to establish Jackson’s intent to commit the crime of larceny once inside the house; (2) that the trial court erred in refusing to give Jackson’s proffered jury instruction for the lesser-included offense of trespass; and (3) that the trial court erred in denying Jackson’s Motion for a Directed Verdict and his Motion for Judgment Notwithstanding the Verdict, or in the Alternative, for a New Trial. Finding no error, the Supreme Court affirmed Jackson's conviction and sentence.

In 2005, Eddie Mitchell shot and killed Cliff Patterson while both were working as mechanics at Anglin Tire in Jackson, Mississippi. Mitchell claimed that he killed Patterson in self-defense. A jury found Mitchell guilty of murder, and as a result, the trial court sentenced Mitchell to life in prison. At issue on appeal was whether the trial court properly instructed the jury on self-defense and manslaughter; whether the trial court erred in admitting evidence of a past physical altercation between Mitchell and a former coworker; whether prosecutorial misconduct existed in cross-examination and closing arguments; and whether trial counsel was ineffective. Upon review, the Supreme Court concluded that the trial court properly instructed the jury on self-defense and manslaughter, and did not err in allowing the prosecution to question Mitchell about a past physical altercation with a former coworker. The Court could not find evidence of prosecutorial misconduct, nor could it substantiate Mitchell's claim of ineffective assistance of counsel. Accordingly, the Court affirmed Mitchell's conviction and sentence.

Defendant Justin Springer was convicted of capital murder by a jury in the Circuit Court of Lee County on May 6, 2011. The underlying felony was burglary. For this conviction, he was sentenced to life in the custody of the Mississippi Department of Corrections, without the possibility of parole. After the trial court's denial of his post-trial motions, Defendant appealed to the Supreme Court, alleging that the verdict was contrary to the overwhelming weight of the evidence. Finding that the verdict against him was not contrary to the overwhelming weight of the evidence, the Court affirmed his conviction and sentence.