Justia Criminal Law Opinion Summaries

Articles Posted in Mississippi Supreme Court
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LeDarius Bonds was convicted by jury of murder and sentenced to life in prison. Bonds appealed his conviction, arguing that the trial court erred in admitting "Exhibit 39," a gruesome photograph that he contended was more prejudicial than probative, and that the trial court erred in allowing a jury instruction which informed the jury that it could infer malice from the use of a deadly weapon. Finding that Exhibit 39 was far more prejudicial than probative, the Supreme Court reversed the conviction and remanded for a new trial. View "Bonds v. Mississippi" on Justia Law

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A jury found Daryl Conner guilty of burglary and felony fleeing a police officer, and the Circuit Court sentenced him as a habitual offender to two consecutive life sentences. Conner appealed to the Court of Appeals, which affirmed his convictions and sentences. On appeal to the Supreme Court, Conner argued the evidence was insufficient to support his conviction for felony fleeing, that the trial court erred by failing to instruct the jury on the elements of larceny, and that, because the pen packs establishing Conner’s habitual-offender status were not admitted at the sentencing hearing, the trial court erred by sentencing him as a habitual offender. The Supreme Court affirmed the appellate and trial courts, finding the evidence was sufficient to support Conner’s felony-fleeing conviction and that the jury was fully and fairly instructed. Furthermore, the pen packs establishing Conner’s status as a habitual offender were admitted at the sentencing hearing. View "Conner v. Mississippi" on Justia Law

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A jury convicted Ryan Abeyta of the murder of his mother, for which he was sentenced to life in the custody of the Mississippi Department of Corrections. Abeyta appealed, arguing that he was entitled to a jury instruction on heat-of-passion manslaughter, that the evidence of deliberate design was insufficient to support the verdict, and that the trial court abused its discretion by admitting gruesome photographs of the victim. Upon review, the Supreme Court concluded Abeyta’s issues were without merit and affirmed the trial court. View "Abeyta v. Mississippi" on Justia Law

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Sixteen-year-old Bernard Taylor fired multiple shots into a car containing five people, wounding three of them. He was charged with three counts of aggravated assault, with each count alleging a firearms enhancement. The trial court denied Taylor’s proposed jury instruction on the lesser-included offense of simple assault. Taylor was granted a self-defense instruction. The jury was not instructed on the firearms enhancement. Taylor was convicted of one count of aggravated assault. Taylor received a twenty-year sentence for aggravated assault and a five-year sentence for a firearms enhancement, to run consecutively. On appeal, Taylor argued that the district court erred by denying the assault instruction, and that the five-year sentence enhancement should be vacated either under “Apprendi v. New Jersey,” (530 U.S. 466), or, alternatively, under double jeopardy. Upon review, the Mississippi Court found that Taylor’s arguments were without merit and affirmed the circuit court. View "Taylor v. Mississippi" on Justia Law

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Brad Hardy appealed his conviction of two counts of manslaughter by culpable negligence and one count of aggravated boating under the influence of alcohol resulting from a boating collision. He was sentenced to forty-four years, with twenty-six to serve. Finding no error, the Supreme Court affirmed. View "Hardy v. Mississippi" on Justia Law

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Gregory Hopkins was convicted as a habitual offender of possession of cocaine with intent to distribute. On appeal he challenged the sufficiency and the weight of the evidence as well as the admission of evidence of his prior bad acts. Finding no error, the Supreme Court affirmed. View "Hopkins v. Mississippi" on Justia Law

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A jury convicted Charles Ervin (a convicted felon) of armed robbery and as a felon in possession of a handgun following the armed robbery of the Healthy Body Store. Police were able to identify Ervin as a suspect after his brother, also a convicted felon, pointed the police in his brother’s direction. At trial, the trial court gave a flight instruction over Ervin's objection. The trial court sentenced him and included a gun enhancement in the sentencing. This appeal followed. Because the trial court improperly limited the defense’s cross-examination of a key State witness, the Supreme Court reversed Ervin’s convictions and remanded the case to the trial court for a new trial. View "Ervin v. Mississippi" on Justia Law

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Eric Moffett was convicted of capital murder and sentenced to death by a jury. Moffett was convicted of a savage sexual assault on a five-year-old girl, resulting in her death. Moffett’s conviction and sentence were affirmed by the Supreme Court on direct appeal, and his motion for rehearing was subsequently denied. Moffett presented a motion, an amended motion, and a supplemental motion seeking post-conviction relief. Moffett's argument to the Supreme Court was focused primarily on ineffective-assistance-of-counsel claims, but finding to merit to any of them, the Supreme Court denied relief. View "Moffett v. Mississippi" on Justia Law

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Scott Smith was convicted of capital murder for the death of seventeen-month-old child and sentenced to life without the possibility of parole. Smith appealed his conviction to the Court of Appeals, arguing that the trial court erred in admitting several Facebook messages and that the testimony of an investigator violated the Confrontation Clause. The Court of Appeals found no reversible error and affirmed. Smith then appealed to the Supreme Court arguing that the Court of Appeals erred: (1) in holding that the Facebook messages were sufficiently authenticated; (2) that the Court of Appeals erred by finding that an email from Facebook was not inadmissible hearsay; and (3) that the Court of Appeals erroneously applied a harmless-error analysis to the violation of Smith’s confrontation rights. The Supreme Court granted certiorari and limited its review to Smith’s claim that the Facebook messages were not sufficiently authenticated. The Court found that Smith’s claim had merit; however, because the error was harmless, the Court affirmed Smith’s conviction and sentence. View "Smith v. Mississippi" on Justia Law

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Derrick Henley appealed his conviction by jury of possession of burglary tools. Upon review, the Supreme Court found that the State failed to present sufficient evidence that the tools were intended to be used in aiding the commission of a burglary. The Court therefore reversed and remanded Henley's conviction and sentence. View "Henley v. Mississippi" on Justia Law