Justia Criminal Law Opinion Summaries

Sacory Brown directly appealed his conviction for burglary of a dwelling to the Supreme Court. Brown received a twenty-five year sentence, with eighteen years to serve and seven years suspended (with five of those years on post-release supervision). On appeal, he argued that the Miranda warning he was given before making an inculpatory statement to the police was insufficient because it did not explicitly inform him of his right to stop talking to the police at any time. He also argued that the twenty-five-year sentence was grossly disproportionate in violation of the Eighth Amendment. Furthermore, he argued that the evidence supporting the verdict was legally insufficient and the verdict was against the overwhelming weight of the evidence. Finding no error, the Supreme Court affirmed Brown's conviction and sentence. View "Brown v. Mississippi" on Justia Law

Defendant Mickey Johnson argued that law enforcement officers gave defective Miranda warnings and coerced his written statement by promising to forego charges against his fiancée. Defendant was ultimately convicted for possession of cocaine. The Supreme Court found defendant's Miranda warnings were not defective, and was not persuaded that the trial court erred in finding defendant voluntarily gave a statement that included his confession. View "Johnson v. Mississippi" on Justia Law

A jury convicted Eboni White of manslaughter, and the trial judge sentenced her to twenty years in the custody of the Mississippi Department of Corrections (MDOC). White appealed, claiming the trial court erred by: (1) refusing to dismiss her indictment based on certain improper influences on the grand jury; (2) prohibiting her expert witness from giving his opinion at trial on the use of force in self-defense; (3) refusing to instruct the jury on her theory of self-defense; and (4) not allowing her witness to testify because he was in the courtroom during the expert's testimony. Additionally, White challenged the weight and sufficiency of the evidence to support her conviction and argued cumulative error. The Court of Appeals affirmed, finding no error. The Supreme Court granted certiorari on the issues of whether the trial court erred by excluding the witness' testimony and denying White’s jury instructions, the Court found error and reversed for a new trial. View "White v. Mississippi" on Justia Law

Levi Jenkins was indicted and on two counts of sexual battery and one count of statutory rape against his then-five-year-old niece. He was convicted only of fondling, a lesser-included offense of the second count of sexual battery. Jenkins appealed, raising various issues. Finding his arguments to be without merit, the Supreme Court affirmed the Circuit Court's judgment. View "Jenkins v. Mississippi" on Justia Law

In 1987, Johnny Ray Magee was convicted of robbing a liquor store and sentenced to a term of life imprisonment as a habitual offender. The Supreme Court affirmed his conviction in 1989 and dismissed his motion for post-conviction relief in 1992. In 2010, the Court granted Magee’s request to amend his PCR on the basis of his claim of newly discovered evidence of juror misconduct. The Circuit Court held an evidentiary hearing to consider this new evidence. The judge found that, when the prospective jurors were asked whether any of them had family or close friends in law enforcement, a juror’s failure to disclose her belief that a local deputy sheriff was her fourth cousin did not amount to juror misconduct and did not prejudice jury selection. The Court of Appeals affirmed. The Supreme Court granted certiorari on the issues of whether the circuit court erred in finding no juror misconduct and whether the circuit court violated Rule 9.04 of the Uniform Rules of Circuit and County Court by allowing the last-minute testimony of a witness at the evidentiary hearing. The Supreme Court affirmed the circuit court’s denial of postconviction relief, finding that no juror misconduct occurred and that, even if a violation of Rule 9.04 occurred, the error was harmless and the issue was waived due to lack of a defense request for a continuance or mistrial. View "Magee v. Mississippi" on Justia Law

Following his convictions for one count of sexual battery and three counts of gratification of lust, Joe Earl Cole argued on appeal that the trial court erred in admitting hearsay and evidence of alleged prior unindicted acts of sexual misconduct with two of his minor granddaughters. Finding no error, the Supreme Court affirmed. View "Cole v. Mississippi" on Justia Law

Rodrique Watson appealed his burglary conviction. When the victim returned home from shopping, she parked her car in an open garage, which was attached to her home. The applicable statute required the State to prove two elements: (1) unlawful breaking and entering the dwelling house and (2) the intent to commit a crime therein. At the jury instruction conference, the State submitted the following: "The Court instructs the Jury that 'breaking' as used in the indictment and in the Court’s instructions, means any act of force, regardless of how slight, which is necessary to be used in entering a building, whether the building be locked or unlocked; The Court further instructs the Jury that the 'force' used to enter the building may be accomplished through the passage of a door, which breaks the plane. Watson objected to the second part of the instruction as a misstatement of the law. The Supreme Court agreed that the trial judge incorrectly instructed the jury that breaking the plane of a door satisfied the force element of burglary of a dwelling. Therefore, the conviction was reversed and the case remanded for a new trial. View "Watson v. Mississippi" on Justia Law

Lisa Sandlin was convicted of murder for the death of her stepson Kirk Sandlin, for which she was sentenced to a term of life in prison. Sandlin appealed, arguing: (1) the trial court erred by allowing Lisa’s husband Sammy Sandlin to testify for the State; and (2) she received ineffective assistance of counsel. After careful consideration, the Supreme Court concluded the first issue was barred from review. But the record was insufficient to consider two of her ineffective-assistance-of-counsel claims, Sammy’s testimony and a 911 call, on direct appeal. Thus, the Court dismissed those two claims without prejudice to Lisa’s right to bring these claims later in a properly filed motion for post-conviction relief. View "Sandlin v. Mississippi" on Justia Law

Anthony Tyrone Thomas was convicted of aggravated assault and of being a felon in possession of a weapon, for which he was sentenced to two consecutive terms of life without parole as a habitual offender. The Court of Appeals affirmed both convictions, and the Supreme Court granted Thomas's petition for writ of certiorari. Because the Supreme Court found that Count II of Thomas's indictment did not charge him with a crime, it reversed his conviction for being a felon in possession of a weapon and dismissed the indictment in Count II. The Court affirmed the trial court in all other respects. View "Thomas v. Mississippi" on Justia Law

John Wrenn pled guilty to possession of a firearm by a convicted felon. He appealed his conviction, arguing: (1) Mississippi’s concealed-weapon statute precluded his conviction; and (2) he was denied effective assistance of counsel. Because Wrenn's conviction was the result of a guilty plea, the Supreme Court dismissed this appeal. View "Wrenn v. Mississippi" on Justia Law