Justia Criminal Law Opinion Summaries

Daniel Beasley appealed an Amite County jury's finding him guilty of murder. Beasley was charged in connection with the death of Janie Wilkinson in 2011. Finding no reversible error, the Supreme Court affirmed the jury's verdict. View "Beasley v. Mississippi" on Justia Law

Edward Cox appealed the Circuit Court’s denial of his motion to dismiss a three-count indictment, which charged him with three counts of aggravated assault under Section 97-3-7 of the Mississippi Code. The issue before the Supreme Court was whether the justice court’s act of revoking Cox’s suspended sentence for a prior misdemeanor assault and sentencing him to a six-month sentence barred the State from prosecuting Cox’s subsequent felony assaults. The Supreme Court held that Cox’s double-jeopardy claim applies only to his original charge, conviction, and sentence, but not his subsequent criminal actions. Therefore, the Supreme Court affirmed the trial court. View "Cox v. Mississippi" on Justia Law

Larry Hammett petitioned for statutory compensation under the legislative act for Compensation to Victims of Wrongful Conviction and Imprisonment. Hammett was found guilty of perjury by a jury in 1997, and was sentenced as a habitual offender to serve ten years in the custody of the Mississippi Department of Corrections (MDOC). In, 2001, having found the State had failed to prove its perjury case against Hammett with sufficient evidence, the Mississippi Court of Appeals reversed and rendered Hammett’s perjury conviction and vacated Hammett’s sentence. In 2009, the Legislature enacted Mississippi Code Section 11-44-1 et seq., which allows compensation for “innocent persons” wrongfully convicted “of one or more felonies and subsequently sentenced to a term of imprisonment,” and who have “served all or any part of the sentence[.]”In 2012, Hammett petitioned for compensation under this provision on the claim that he had spent five years in prison for a wrongful conviction. The trial court found that Hammett had filed his claim on October 5, 2012, and dismissed the claim because it found the claim time-barred. The Supreme Court reversed. Although Hammett did not file his complaint with the court, he contends that he filed it with prison officials, and the prison mailbox rule applies. The Supreme Court found that a question exists as to whether it did. Based on the record, Hammett submitted his petition for statutory compensation to prison officials for mailing on May 24, 2012. But he failed to include either a filing fee or an IFP affidavit along with it. On June 19, 2012, Hammett had an IFP affidavit notarized. But the record was inconclusive as to whether Hammett resubmitted his complaint along with the notarized IFP affidavit to prison officials for mailing to the Adams County Circuit Clerk’s office prior to the June 30, 2012, deadline. View "Hammett v. Mississippi" on Justia Law

After being convicted by jury for statutory rape and resisting arrest, defendant Toney Jennings was sentenced to fifteen years: ten years to serve and five years suspended. Jennings received six months for resisting arrest. Jennings appealed the statutory-rape conviction. The Court of Appeals affirmed. The issue before the Supreme Court in this matter centered on whether the trial court erred in admitting Jennings’s arguably involuntary statement to police into evidence. After review, the Court concluded the State clearly failed to prove beyond a reasonable doubt that Jennings’s waiver and statement were voluntary, knowing, and intelligent, given the many problems surrounding the waiver and the "dearth" of evidence supporting its voluntariness. The Court reversed and remanded the case for a new trial and a new and reliable suppression hearing in which a specific determination regarding voluntariness could be made, and a record adequately developed. View "Jennings v. Mississippi" on Justia Law

Michael Ambrose was indicted for capital murder while in the commission of a robbery in Harrison County, Mississippi. After trial, the jury acquitted Ambrose of capital murder but found him guilty of deliberate design murder. The trial court sentenced Ambrose to life imprisonment. Ambrose appealed. Upon review, the Supreme Court affirmed Ambrose’s conviction and sentence, finding that the evidence was sufficient to support a murder verdict and the verdict was not against the overwhelming weight of the evidence. View "Ambrose v. Mississippi" on Justia Law

The State indicted John Bartholomew Lowe on five counts of exploitation of a child, alleging that he had downloaded sexually explicit images and videos of children from the internet to his personal computer. The State had no direct evidence that Lowe had downloaded the images; its case depended on the opinions of its expert witness. On appeal of his eventual conviction, Lowe contended that several others had access to his computer, and that someone else had downloaded the material. He requested funds to hire an expert to help prepare his case to refute the State’s expert. The trial court denied Lowe’s request. The Supreme Court concluded that denial deprived Lowe of the opportunity to prepare an adequate defense. Therefore the Supreme Court reversed his conviction and remanded the case for a new trial. View "Lowe v. Mississippi" on Justia Law

Jason Hall was indicted and tried on an indictment for burglary of a building. After both sides rested, the State requested and was granted a jury instruction for accessory after the fact to burglary (in addition to the burglary instruction). The jury acquitted Hall of burglary but convicted him of accessory after the fact to burglary. Because Hall was convicted of a crime for which he was not indicted, nor did he waive indictment, the Supreme Court reversed the conviction and vacate Hall's sentence. View "Hall v. Mississippi" on Justia Law

Regina Dees was convicted of arson and insurance fraud. For arson, the circuit court sentenced Dees to ten years in the custody of the Mississippi Department of Corrections, with two years to serve and eight years suspended, with three years on post-release supervision. For insurance fraud, the court sentenced Dees to two years to run concurrently with the arson sentence. Dees appealed the convictions and sentences, challenging the sufficiency of the evidence supporting both convictions. Because the evidence sufficiently supported the convictions, the Supreme Court affirmed. View "Dees v. Mississippi" on Justia Law

Lee Darrell Nix appealed a Court of Appeals judgment affirming the Circuit Court’s denial of his motion for post-conviction relief (PCR). Nix was convicted of touching a child for lustful purposes and kidnapping. His conviction was unanimously affirmed by the Supreme Court on direct appeal. On PCR, Nix argued that the State failed to prove beyond a reasonable doubt an essential element of the crime. The Supreme Court concluded that Nix failed to carry his burden showing he was entitled to relief. As such, the trial court did not err in denying his petition. View "Nix v. Mississippi" on Justia Law

Yardley Shelton Lyons was indicted for carjacking (Count I) and kidnapping (Count II). The indictment accused Lyons of perpetrating these acts against persons over the age of sixty-five years, subjecting him to the elderly sentence enhancement which allowed the court to sentence him to twice the maximum statutory sentence for both counts. After finding Lyons guilty on both counts, the jury also found that he was eligible for the elderly sentence enhancement. The trial court did not impose the sentence enhancement, and instead sentenced Lyons to fifteen years for carjacking and twenty-five years for kidnapping, to be served consecutively. The court later amended Lyons's sentence on Count II, reducing it from twenty-five years to fifteen years. Lyons filed a motion for judgment notwithstanding the verdict (JNOV), or for a new trial. This motion was denied. Lyons appealed. After reading the entire transcript and record, the Supreme Court was unable to discern any issues which would warrant additional briefing or reversal. Accordingly, the Court affirmed Lyons' convictions and sentences. View "Lyons v. Mississippi" on Justia Law