Justia Criminal Law Opinion Summaries

On July 9, 2022, Officer Cody Moulds of the Magee Police Department stopped Doyle Ray Middleton, Jr. for driving a motorcycle without a tag. Middleton, who only had a state ID card, consented to a search, and Officer Moulds found a bag containing a crystal-like substance. Middleton was issued tickets for an expired tag and misdemeanor possession of a controlled substance and was taken into custody. The substance was later determined to be a felony amount of narcotics.The Magee Municipal Court scheduled Middleton's court date for August 2, 2022, but he failed to appear. The court sent letters informing him of fines for the tickets and warned of a bench warrant if the fines were not paid. Middleton did not pay the fines, leading to a bench warrant and a notice of license suspension. On September 5, 2023, a Simpson County grand jury indicted Middleton for felony possession of methamphetamine. Middleton moved to dismiss the indictment, arguing double jeopardy, but the circuit court denied the motion, finding no prior conviction.The Supreme Court of Mississippi reviewed the case. Middleton argued that the municipal court's fine determination constituted a conviction, thus barring the felony indictment under double jeopardy. The State contended that the municipal court lacked jurisdiction over felony charges and that no conviction occurred. The court found no evidence of a conviction for misdemeanor possession in the municipal court, as the record only showed a fine determination and failure to appear, not a guilty disposition or fine payment.The Supreme Court of Mississippi held that Middleton had not been placed in double jeopardy because he failed to prove a prior conviction for the same offense. The court affirmed the trial court's denial of Middleton's motion to dismiss and remanded the case. View "Middleton v. State of Mississippi" on Justia Law

Staci Broome was convicted of aggravated assault after an altercation with Julie Mathis, the daughter of Broome's boyfriend, Michael Mathis. The incident occurred when Julie was at her father's house doing schoolwork, and Broome, upon learning of Julie's presence, confronted her. The confrontation escalated into a physical fight, during which Broome hit Julie with a metal object, causing significant injuries.The case was initially tried in the Simpson County Circuit Court, where the jury found Broome guilty of aggravated assault. Broome was sentenced to twenty years, with fifteen years to serve and five years of supervised probation. Broome appealed her conviction, arguing that the trial court erred by allowing hearsay testimony and lay opinion testimony on the ultimate issue.The Supreme Court of Mississippi reviewed the case. Broome contended that the trial court improperly admitted hearsay testimony from Investigator Brian Green, who testified about statements made by Julie Mathis during his investigation. The court found that Green's testimony about the metal object was not hearsay because it was offered to explain the steps he took during his investigation. Although the court acknowledged that Green's repetition of Julie's identification of Broome was hearsay, it deemed the error harmless given the overwhelming evidence against Broome.Broome also argued that the trial court erred by allowing Green to express his opinion on the ultimate issue of the case. The Supreme Court found that any error in admitting this testimony was harmless due to the substantial evidence presented by the State, including testimonies from Julie, Amber (Broome's daughter), and Michael, as well as physical evidence.The Supreme Court of Mississippi affirmed Broome's conviction and sentence. View "Broome v. State of Mississippi" on Justia Law

Lavern Kendrick was convicted in the Puckett, Mississippi, Municipal Court of misdemeanor driving under the influence (DUI), first offense, and possession of drug paraphernalia. The charges stemmed from a traffic stop at a safety checkpoint where officers observed a meth pipe in Kendrick's vehicle and detected the smell of methamphetamine. Kendrick admitted to possessing and recently using methamphetamine. He was arrested and convicted in municipal court.Kendrick appealed to the Rankin County County Court for a trial de novo, where he filed a motion to suppress the evidence, arguing that the traffic stop was unlawful. The county court denied the motion and found Kendrick guilty of both charges. The Rankin County Circuit Court affirmed the convictions on appeal.The Supreme Court of Mississippi reviewed the case, focusing on whether the safety checkpoint was constitutional. The court considered the testimony of the officers involved, who stated that the checkpoint's primary purpose was to check for driver's licenses and insurance. Despite some inconsistencies in the testimony of the less experienced officer, the court found that the checkpoint served a legitimate public interest and was not primarily for general crime control.The Supreme Court of Mississippi held that the safety checkpoint was permissible under the Fourth Amendment and the Mississippi Constitution, as it served a legitimate public interest and minimally intruded on individual liberty. The court affirmed Kendrick's misdemeanor convictions. View "Kendrick v. State of Mississippi" on Justia Law

Brandon J. Barnett was convicted of selling methamphetamine after a confidential informant, Kimberly Dido, arranged a controlled buy with him. Dido, who had previously bought drugs from Barnett, was working with the Jones County Sheriff’s Department in exchange for having her charges dropped. During the controlled buy, Dido was fitted with a hidden camera and given marked bills to purchase drugs from Barnett. The substance obtained was later confirmed to be 3.01 grams of methamphetamine.At trial, the forensic analyst who tested the substance did not testify. Instead, a different analyst, Charlotte Cothern, testified as a technical reviewer, stating that she agreed with the test results. Barnett’s counsel highlighted that Cothern did not personally test the substance. The trial court granted a jury instruction (Instruction S-3A) stating that it was permissible for a technical reviewer to testify in place of the primary analyst, which Barnett objected to, arguing it improperly commented on the weight of the evidence.The Mississippi Supreme Court reviewed the case and found that the trial court erred in giving Instruction S-3A. The court held that the instruction improperly commented on the weight and credibility of the technical reviewer’s testimony, which are matters for the jury to decide. The court emphasized that while the admissibility of the testimony is a legal question for the judge, the weight and credibility are exclusively for the jury. Consequently, the court reversed Barnett’s conviction and remanded the case for a new trial. View "Barnett v. State of Mississippi" on Justia Law

Donald Quinn was indicted for the sexual battery of his seventeen-year-old niece, resulting in her pregnancy. The indictment was amended to reflect the crime occurred between July 1, 2015, and May 25, 2016. Pretrial motions included the exclusion of hearsay statements from the victim and her mother, who were unavailable to testify. The trial court allowed limited testimony from Detective Neal and admitted DNA evidence linking Quinn to the child.The Hinds County Circuit Court convicted Quinn, sentencing him to twenty years, with ten years suspended. Quinn's motion for judgment notwithstanding the verdict or a new trial was denied. On appeal, the Court of Appeals reversed the conviction, citing insufficient proof of venue and potential issues with witness testimony and evidence admission.The Supreme Court of Mississippi reviewed the case on certiorari. The court found that the trial court did not err in its rulings. It held that the State sufficiently proved venue through Detective Neal's unobjected-to testimony, which established the crime occurred in Hinds County. The court also found no error in admitting Dr. Schiro's DNA testimony, as he was sufficiently involved in the analysis and report. The amendment to the indictment was deemed proper, as it did not prejudice Quinn's defense. Carolyn Smith's testimony was allowed despite late disclosure, as it did not result in manifest injustice. The court also ruled that the trial court properly handled the State's closing argument and the use of birth certificates to refresh Smith's memory.The Supreme Court of Mississippi reversed the Court of Appeals' decision and reinstated and affirmed the Hinds County Circuit Court's judgment. View "Quinn v. State" on Justia Law

Holly Mitchell was found guilty of second-degree murder and possession of methamphetamine after she shot and killed her husband, Shawn Mitchell, in their home while holding their three-year-old daughter. Holly claimed she acted in self-defense because Shawn was violent and had been using meth. Witnesses testified about the couple's tumultuous relationship, marked by drug use and domestic violence. Holly's defense argued the shooting was accidental, while the prosecution presented evidence of premeditation.The Marion County Circuit Court jury convicted Holly of second-degree murder. During deliberations, the jury expressed confusion about the instructions regarding second-degree murder and manslaughter. The trial court provided clarifications, but Holly's defense did not object to the court's responses. Holly appealed, arguing that the jury instructions were confusing and that her trial counsel was ineffective for not requesting additional instructions on imperfect-self-defense and culpable-negligence manslaughter.The Supreme Court of Mississippi reviewed the case and found no reversible error in the jury instructions, stating they were clear and properly guided the jury's deliberations. The court also noted that the jury ultimately reached a unanimous decision. Regarding the ineffective assistance of counsel claim, the court determined that the issue was best addressed in a post-conviction proceeding due to the lack of a fully developed record on direct appeal.The Supreme Court of Mississippi affirmed Holly's conviction for second-degree murder, dismissing her ineffective assistance of counsel claim without prejudice, allowing her to raise it in a post-conviction proceeding if she chooses. View "Mitchell v. State" on Justia Law

Caleb Corrothers was convicted of two counts of capital murder and one count of aggravated assault after attacking Tonya Clark’s family, resulting in the deaths of her husband and son. The jury sentenced him to death for the murders and life for the assault. Corrothers appealed, but the Supreme Court of Mississippi affirmed his convictions and sentences.Corrothers then sought post-conviction relief, raising multiple issues. The Supreme Court of Mississippi denied all but one claim, which alleged that a female juror had improperly communicated with Clark during the trial. The court granted a hearing on this juror-bias claim. Six years later, an evidentiary hearing was held where Corrothers presented two witnesses, his mother and cousin, who testified they saw the juror mouth “we got it” to Clark. The trial judge found these witnesses not credible due to their personal interest in the case and denied post-conviction relief.Corrothers appealed this decision, arguing that the trial judge improperly disregarded his witnesses' testimony and that his right to compulsory process was denied. The Supreme Court of Mississippi found that the trial judge did not exclude the testimony but rather found it not credible, a determination to which the court must defer. The court also held that the procedural framework established in Gladney v. Clarksdale Beverage Co. applied to Corrothers’s juror-bias claim, and the trial judge did not err in denying additional juror interviews.Ultimately, the Supreme Court of Mississippi affirmed the trial court’s denial of Corrothers’s post-conviction relief, concluding that Corrothers failed to present credible evidence of juror bias. View "Corrothers v. State" on Justia Law

Diamante Myers was charged with shooting into a dwelling and aggravated assault with a deadly weapon. The incident occurred on November 2, 2020, in Picayune, Mississippi, where Myers approached Abasi Bolden, who was cooking in his yard. After a verbal altercation, Myers threw an object at Bolden, leading to a physical fight. Myers later returned with a gun and fired shots, hitting a nearby house and shattering a window. Myers was wearing an ankle monitor, and data from the monitor placed him at the scene. He was arrested nearby, and gunshot residue was found on his hands.The Pearl River County Circuit Court tried Myers in June 2023. The jury found him guilty on both charges. Myers appealed, arguing that the trial court committed plain error by granting jury instruction S-3, which he claimed constituted an impermissible constructive amendment to his indictment. The trial court had denied Myers's motion for a directed verdict after the prosecution rested its case.The Supreme Court of Mississippi reviewed the case. The court held that the language used in jury instruction S-3 did not constitute an impermissible constructive amendment to Myers's indictment. The court found that the instruction did not materially alter the essential elements of the offense or any defense Myers had. Therefore, the trial court's decision to grant the instruction was not plain error. The Supreme Court of Mississippi affirmed the lower court's decision, upholding Myers's convictions. View "Myers v. State of Mississippi" on Justia Law

Lyncoya Ratcliff was convicted of possession of a weapon by a felon and possession of a stolen firearm. He was pulled over by police for a broken headlight, and during the stop, officers found a stolen firearm in the vehicle. Ratcliff denied knowledge of the firearm but admitted ownership of a bag containing ammunition matching the stolen weapon. He was subsequently arrested and convicted on both charges.The Forrest County Circuit Court denied Ratcliff's motion for judgment notwithstanding the verdict, and he appealed. The Court of Appeals affirmed his convictions. Ratcliff then filed a petition for certiorari, which the Supreme Court of Mississippi granted, focusing solely on his conviction for possession of a stolen firearm.The Supreme Court of Mississippi reviewed the case de novo, considering whether the evidence was sufficient to support Ratcliff's conviction for possession of a stolen firearm. The court found that the evidence presented did not exclude the reasonable hypothesis that Ratcliff hid the weapon because he was a convicted felon, not because he knew it was stolen. The court noted that the State failed to provide sufficient evidence of Ratcliff's guilty knowledge that the firearm was stolen, as required by precedent cases such as Barton v. State.The Supreme Court of Mississippi reversed and rendered Ratcliff's conviction for possession of a stolen firearm, finding that the State did not meet its burden of proving guilty knowledge beyond a reasonable doubt. The court did not address Ratcliff's conviction for possession of a weapon by a felon, as it was not raised in the petition for certiorari. View "Ratcliff v. State of Mississippi" on Justia Law

Rudy Toler fired his handgun at four youths while traveling on Highway 90 between Pass Christian and Gulfport in 2021. This led to a high-speed chase during which Toler fired two more shots at pursuing officers. A Harrison County grand jury indicted Toler on ten felony charges, including multiple counts of aggravated assault and failure to stop for law enforcement. In 2023, a jury found Toler guilty on most counts, except for one count of aggravated assault against an officer.The Harrison County Circuit Court sentenced Toler to a total of forty years in prison. Toler appealed, arguing that the evidence was insufficient to support several of the convictions and that the trial court erred in excluding evidence of his peaceful character.The Supreme Court of Mississippi reviewed the case. The court found that the evidence was sufficient to support the convictions for aggravated assault against the officers and one count of aggravated assault against the youths. However, the court determined that the indictment was multiplicitous regarding the four counts of aggravated assault against the youths, as they were based on a single act of firing one shot. The court held that these counts should be merged into one.The Supreme Court of Mississippi affirmed the convictions in part, reversed in part, and remanded the case to the trial court to vacate the sentences for the four multiplicitous counts, merge them into one count, and resentence Toler accordingly. The court also found that the trial court did not abuse its discretion in excluding evidence of Toler’s peaceful character. View "Toler v. State of Mississippi" on Justia Law