Justia Criminal Law Opinion Summaries

Tony Clark was convicted of capital murder, attempted murder, and possession of a firearm by a previously convicted felon. His death sentence was affirmed by the Mississippi Supreme Court, and the United States Supreme Court denied his petition for writ of certiorari. Clark subsequently filed his first motion for post-conviction relief, claiming intellectual disability and ineffective assistance of counsel, among other issues.The Madison County Circuit Court initially reviewed the case, and the Mississippi Supreme Court affirmed Clark's convictions and sentence. Clark then sought post-conviction relief, which led to the current appeal.The Supreme Court of Mississippi reviewed Clark's motion for post-conviction relief. The court granted the motion in part, remanding the case to the Madison County Circuit Court for an Atkins hearing to determine if Clark is intellectually disabled, which would make him ineligible for execution under the Eighth Amendment. The court found that Clark presented sufficient evidence, including affidavits from medical professionals, to warrant a hearing on his intellectual disability claim. However, the court denied all other claims, including ineffective assistance of counsel related to mitigation evidence, Batson challenges, jury wheel issues, the avoiding arrest aggravator, jurors' racial bias, and jury instructions. The court also rejected Clark's cumulative error argument. The decision was to grant post-conviction relief in part and deny it in part. View "Clark v. State" on Justia Law

Mercedes B. Clark was stopped by Officer Ricky Robinson for speeding and driving on the wrong side of the road. During the stop, Officer Robinson smelled burnt marijuana and conducted a DUI investigation. A search of Clark's vehicle revealed a clutch bag containing a half-smoked marijuana joint, multicolored pills, and items with Clark's name. Clark admitted the bag was hers but claimed a male acquaintance had put his belongings in it, which she thought was marijuana.A Lauderdale County jury found Clark guilty of trafficking eutylone, a Schedule I controlled substance. The trial court sentenced her to ten years without parole. Clark's appellate counsel filed a brief under Lindsey v. State, stating no arguable issues for appeal. Clark filed a pro se supplemental brief raising three issues: the exclusion of her after-arrest interview, improper jury instructions, and a request for parole eligibility for first-time offenders.The Supreme Court of Mississippi reviewed the case. The court found that Clark had agreed to the exclusion of her interview with Agent Wilburn, making her argument on this point meritless. The court also determined that the jury instructions were proper, as they required the jury to find that Clark "unlawfully, wilfully, and feloniously" possessed the eutylone, which implicitly included the requirement of knowing possession. Lastly, the court noted that it does not have the authority to amend statutes, thus denying Clark's request for parole eligibility.The Supreme Court of Mississippi affirmed Clark's conviction and sentence, finding no arguable issues warranting relief. View "Clark v. State of Mississippi" on Justia Law

A man was charged with six counts of statutory rape involving his eleven-year-old daughter, who lived with him after her mother was incarcerated. The daughter testified that her father raped her on multiple occasions, providing detailed accounts of the assaults. Evidence included her birth certificate, which established both her and her father’s ages, and testimony from family members and investigators. The defendant denied the allegations, suggesting the accusations were fabricated due to disciplinary issues.The Circuit Court of Yazoo County conducted a jury trial, during which the defendant’s counsel submitted jury instructions that omitted the statutory requirement that the defendant be at least twenty-four months older than the victim. The State agreed to use the defense’s instructions. The jury convicted the defendant on all counts, and he was sentenced to thirty years’ imprisonment. On appeal, the Mississippi Court of Appeals reversed the conviction, holding that the omission of the age-gap element from the jury instructions constituted reversible error.The Supreme Court of Mississippi reviewed the case on certiorari. It held that, under the invited-error doctrine, a defendant cannot complain on appeal about an error in jury instructions that he himself requested and received. The Court found that the defendant was estopped from challenging the omission of the age-gap element, as he had submitted the instructions and the State and trial court had accepted them. The Court also rejected the defendant’s other claims, including ineffective assistance of counsel, sufficiency of the evidence regarding venue, improper admission of hearsay, and a Batson challenge. The Supreme Court of Mississippi reversed the Court of Appeals’ decision and reinstated and affirmed the conviction and sentence imposed by the Circuit Court of Yazoo County. View "Allen v. State" on Justia Law

In October 2019, April Jones and Will Polk were reported missing. The investigation stalled until 2021 when Keith Coleman, Jr. confessed to shooting and dismembering them. Coleman was indicted on two counts of first-degree murder and two counts of desecration of a corpse. At trial, Coleman claimed his girlfriend, Chelsea Golden, was the actual shooter, and he had previously confessed to protect her. The jury found Coleman guilty on all counts, and he was sentenced to two consecutive life terms for the murders and three years for each desecration count, to run concurrently.Coleman appealed his convictions, arguing that the verdict was against the overwhelming weight of the evidence. He claimed his confession was coerced to protect Golden and that the State's witnesses were unreliable. The Mississippi Supreme Court reviewed the case, noting that the jury is responsible for resolving conflicts in testimony and determining witness credibility. The court found that the jury had ample testimonial evidence to support the verdict, despite the lack of physical evidence directly linking Coleman to the crime.The Mississippi Supreme Court held that the jury's verdict was not against the overwhelming weight of the evidence and affirmed Coleman's convictions. The court emphasized that issues of witness credibility and conflicting testimony are for the jury to resolve, and the absence of physical evidence does not negate a conviction when there is sufficient testimonial evidence. View "Coleman v. State of Mississippi" on Justia Law

In 2022, Jayme Lynn Tubbs was indicted by a Quitman County Grand Jury along with Keith Coleman Jr. for conspiring to commit murder, first-degree murder, and desecration of a human corpse. They were tried jointly, and after the State rested its case, the trial judge dismissed the conspiracy charges. The jury found both defendants guilty on all other counts. Tubbs moved for a judgment notwithstanding the verdict or a new trial, which was denied. After Tubbs appealed, the trial court granted Coleman a new trial due to a discovery violation. Tubbs's appeal was stayed for an evidentiary hearing, which found a Brady violation, leading to a new trial for Tubbs.In September 2023, Tubbs and Coleman were retried and found guilty on all counts. Tubbs was sentenced to life imprisonment for the murders and three years for desecration of a human corpse, to run concurrently. Tubbs again moved for a judgment notwithstanding the verdict or a new trial, which was denied.The Supreme Court of Mississippi reviewed the case. Tubbs raised two issues: the sufficiency of the evidence for her murder convictions and the admissibility of Chief Deputy Peter Clinton’s testimony regarding her confession. The court found sufficient evidence to support the convictions, noting Tubbs's active participation in the planning, execution, and aftermath of the murders. The court also ruled that Clinton’s testimony was not hearsay under Mississippi Rule of Evidence 801(d)(2)(A) and that the best evidence rule did not apply to exclude his testimony. The court affirmed Tubbs's convictions and sentences. View "Tubbs v. State of Mississippi" on Justia Law

Damaris Quinn was convicted in the Clay County Circuit Court of attempted murder and possession of a firearm by a convicted felon. The incident occurred on October 18, 2016, when Quinn shot his wife, Basheeba Ward, five times with a .32 caliber revolver. The shooting took place at Quinn's mother's house, where the couple was living. Ward survived the shooting and testified that Quinn shot her after an argument about her not wearing her wedding ring. Quinn's aunt and mother also provided testimony about the events surrounding the shooting.The jury found Quinn guilty of both charges. Quinn appealed his attempted murder conviction, arguing that the trial court erred by denying a jury instruction related to his defense and that there was insufficient evidence to support his conviction. The trial court had denied a motion for a directed verdict on the attempted murder charge, asserting that the State failed to establish the element of intent for attempted murder.The Supreme Court of Mississippi reviewed the case and found no merit in Quinn's claims. The court held that the jury instruction provided by the trial court properly tracked the attempted-murder statute and that the evidence presented at trial was sufficient for a reasonable jury to find Quinn guilty beyond a reasonable doubt. The court noted that intent could be inferred from Quinn's actions, including shooting Ward multiple times and reloading the gun. The court affirmed Quinn's convictions for attempted murder and possession of a firearm by a convicted felon. View "Quinn v. State of Mississippi" on Justia Law

Attorney Zachary Jex was hired to defend Jerrell Davis on charges of first-degree murder and aggravated assault. After a mistrial in January 2022, a second trial was scheduled for September 12, 2023. During jury selection, the trial was delayed due to a malfunctioning air conditioner. The next day, Jex negotiated a plea deal for Davis, which included dropping the aggravated assault charge and pleading guilty to two counts of manslaughter. The prosecution agreed, but the judge required Jex to pay the jury costs as a condition for accepting the plea.The Claiborne County Circuit Court issued an order requiring Jex to pay $4,141 for the jury costs. Jex contested this order, arguing that he should not be responsible for the costs. The court treated his argument as a motion to reconsider and denied it. Jex then submitted a written motion to reconsider, which was also denied, leading to his appeal.The Supreme Court of Mississippi reviewed the case. The court found that Jex had voluntarily agreed to pay the jury costs during the plea hearing and that the trial judge had the authority to impose these costs under Rule 3.13 of the Uniform Civil Rules of Circuit and County Court Practice. The court also rejected Jex's arguments that he was under duress, that Rule 3.13 was misapplied, and that the prosecution's actions constituted misconduct.The Supreme Court of Mississippi affirmed the order of the Claiborne County Circuit Court, holding that Jex was required to pay the jury costs as he had agreed during the plea negotiations. View "In Re: Jex" on Justia Law

Eltory Hawkins was convicted by a jury of one count of sexual battery and two counts of fondling his girlfriend’s minor daughter. The Desoto County Circuit Court sentenced him to thirty-five years for sexual battery, ten years for each count of fondling (to run consecutively with the thirty-five years and concurrently with each other), and five years of post-release supervision. Hawkins was also required to register as a sex offender.Hawkins's first trial in March 2022 ended in a mistrial due to juror misconduct. Juror 86 was dismissed for inappropriate behavior, including communicating with other jurors and an audience member. Another juror, Juror 3, disclosed knowing a defense witness but claimed impartiality. The circuit court declared a mistrial, citing potential jury taint. Hawkins's motion to dismiss the case on double jeopardy grounds was denied, and a second trial was scheduled.In the second trial in November 2022, the State presented testimony from several witnesses, including the victims. Lily testified that Hawkins had sexually assaulted her multiple times. Hawkins moved for a directed verdict, arguing insufficient evidence, but the motion was denied. The jury found Hawkins guilty on three counts, and he was sentenced accordingly.The Supreme Court of Mississippi reviewed the case and affirmed the conviction and sentence. The court held that the evidence was sufficient to support the convictions, as Lily's testimony alone was enough for a reasonable juror to find Hawkins guilty beyond a reasonable doubt. The court also found that the jury's verdict was not against the overwhelming weight of the evidence. Lastly, the court ruled that the mistrial in the first trial was justified due to manifest necessity, given the juror misconduct, and did not violate Hawkins's protection against double jeopardy. View "Hawkins v. State" on Justia Law

Jakeviyon Hunter was convicted of first-degree murder and shooting into an occupied vehicle. The incident occurred after Hunter and the victim, Jaquarius Ross, were involved in a traffic stop where marijuana and guns were found in the vehicle. Hunter and Ross were both charged with possession of a controlled substance. Later, Hunter shot Ross multiple times while Ross was in his truck, resulting in Ross's death. The prosecution argued that Hunter's motive was related to the earlier drug charge, which could have negatively impacted Hunter's military career.The Madison County Circuit Court sentenced Hunter to life imprisonment for first-degree murder and five years for shooting into an occupied vehicle. Hunter's post-trial motion was denied by the circuit court. He appealed, arguing that the admission of evidence related to his prior misdemeanor charge was improper and raised several claims of ineffective assistance of counsel.The Supreme Court of Mississippi reviewed the case and found no error in the circuit court's admission of the evidence. The court held that the evidence of Hunter's prior drug charge was admissible under Mississippi Rule of Evidence 404(b) to show motive, intent, plan, and identity. The court also provided a limiting instruction to the jury regarding the use of this evidence. The court found that the evidence was necessary to provide a complete story of the events leading to Ross's murder.Hunter's claims of ineffective assistance of counsel were not addressed on direct appeal because his pro se supplemental brief was filed untimely. The court affirmed Hunter's conviction and sentence, finding no plain error in the admission of the evidence. Hunter may still pursue his ineffective assistance claims under the Mississippi Uniform Post-Conviction Collateral Relief Act. View "Hunter v. State of Mississippi" on Justia Law

Raymond Phillips was convicted of attempted aggravated assault after Ronald Brown reported that Phillips had shot at him in Hattiesburg, Mississippi. Brown called 911, and officers arrived to find him distraught. Officer Ianconangelo found a shell casing at the scene, and Officer Truss, who knew Phillips, identified him as the suspect. Phillips was later found driving his truck, which contained a firearm matching the shell casing. Detective Daniels reviewed NOLA camera footage showing Phillips pointing and firing a gun in Brown's direction. The firearm and shell casing were confirmed to match by a forensic examiner.The Forrest County Circuit Court found Phillips guilty of attempted aggravated assault and possession of a weapon by a convicted felon. Phillips was sentenced to twenty years for the assault and ten years for the weapon charge, to be served concurrently. Phillips filed a motion for judgment notwithstanding the verdict or a new trial, which was denied.The Supreme Court of Mississippi reviewed the case. Phillips argued that his Sixth Amendment right to confrontation was violated by the admission of body-camera footage and a search warrant affidavit containing Brown's statements. The court found that the statements on the body-camera footage were non-testimonial as they were made during an ongoing emergency. The court also found that the admission of the search warrant affidavit, which included comments on Phillips's post-Miranda silence, was harmless error given the overwhelming evidence against him. Phillips's claims of cumulative error and ineffective assistance of counsel were also rejected. The court affirmed the lower court's decision, upholding Phillips's conviction. View "Phillips v. State" on Justia Law