Justia Criminal Law Opinion Summaries

Articles Posted in Supreme Court of Mississippi
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A grand jury indicted Dwayne Wilson on one count of aggravated assault. The indictment charges that Wilson “unlawfully, willfully, purposely and feloniously attempt[ed] to cause or knowingly caused bodily injury to . . . Stacy Pierce[] by striking him multiple times in the ribs and mouth with a bat, a means likely to produce death or serious bodily harm[.]” Wilson pled not guilty, but he was ultimately convicted on that charge when his first trial ended in a mistrial. On appeal, Wilson contended the second trial violated his constitutional protection against double jeopardy. Additionally, Wilson claimed the verdict was against the overwhelming weight of the evidence. The Mississippi Supreme Court concluded that although the protections against double jeopardy had attached, the trial court did not abuse its discretion by finding manifest necessity to grant a mistrial. Further, the Court found the verdict in the second trial was not against the overwhelming weight of the evidence presented. Accordingly, judgment and conviction were affirmed. View "Wilson v. Mississippi" on Justia Law

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Soon after the Mississippi Supreme Court appointed counsel to represent death-row inmate Alberto Garcia in post-conviction proceedings before it challenging his death sentence, the Attorney General preemptively filed in the trial court a “Motion for Notice of and an Opportunity to Be Heard on Requests for Litigation Expenses.” Relying on Mississippi Rule of Appellate Procedure 22(c)(3), the Attorney General asserted her office was entitled to notice and an opportunity to be heard on Garcia’s requests for litigation expenses. Even though Garcia’s counsel had made no such request, the trial court granted the motion. The Supreme Court vacated this ruling: "Under Rule 22(c)(3), the Attorney General is not entitled to notice and an opportunity to be heard on a request for litigation expenses that was never made—and will never be made—because Garcia’s appointed attorneys are not compensated and reimbursed through court-approved expenses but rather through their state employer. ... So the Attorney General’s request was not only premature; it was inapplicable. Thus, the trial court lacked authority to grant the Attorney General’s motion." View "Garcia v. Mississippi" on Justia Law

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Courtney Williams appeals her manslaughter conviction. James Williams, his pregnant daughter Courtney, and Courtney’s two children lived with James at James’s residence. James had recently allowed Courtney’s boyfriend, Cymonde “CJ” Sailer, to move in with them. On the night of September 1, 2019, Courtney, her daughter, and CJ were in Courtney’s bedroom watching television. Between 10:30-11:00 p.m., James discovered that CJ had fallen asleep in Courtney’s bed despite an agreement that CJ would sleep in Courtney’s son’s bedroom across the hall. An altercation occurred between James and Courtney. During the altercation, Courtney stabbed James twice in the back. When law enforcement arrived, Courtney advised that her father had attacked her and that she had stabbed her father in the back. One of the law enforcement officers then left to check on James. James was found deceased inside of his vehicle outside of his residence. He was in the driver’s seat, leaned over with his head down. A forensic pathologist who performed James' autopsy found his blood alcohol level was about one and one half times the legal limit. The physician opined the cause of death was “stabbing of the torso” and that the manner of death was homicide. Courtney was indicted and charged with the first-degree murder of James. The Mississippi Supreme Court determined the trial court erroneously refused Courtney's proposed jury instructions related to her right to stand her ground, her conviction and sentence were reversed and the case remanded for a new trial. View "Williams v. Mississippi" on Justia Law

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Willie Manning was convicted in 1994 of two counts of capital murder while engaged in commission of a robbery for the murders of Jon Steckler and Tiffany Miller, and was sentenced to death. Manning appealed, asking the Mississippi Supreme Court to allow him to transfer DNA evidence gathered from the crime scene of the murders of Miller and Stecker to a different specialized lab for additional advanced DNA testing. After many years of pursuing options for DNA testing and fingerprint analysis of evidence used against him at trial, pursuant to Mississippi Code Section 99-39-5 (Rev. 2020), the Supreme Court partially granted Manning’s request for post-conviction collateral relief (PCR). Under the Court’s order, Manning proceeded with DNA analysis and fingerprint comparison utilizing the procedures set forth in the statute. For six years, Manning had DNA evidence tested and expert fingerprint analysis performed. After receiving allegedly inconclusive results, Manning appealed here the circuit court’s order denying his motion to transfer the DNA evidence to a different facility for additional DNA testing. The Supreme Court found the circuit court did not abuse its discretion and affirmed the denial of the request for additional testing. View "Manning v. State of Mississippi" on Justia Law

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Jelani Miles was convicted of shooting into a vehicle, aggravated assault, and second-degree murder. A circuit court sentenced Miles to five years for shooting into a vehicle, twenty years with five years suspended for aggravated assault, and life for second-degree murder, with all sentences to run consecutively. Miles appealed, and the Mississippi Supreme Court deflected his appeal to the Court of Appeals, which affirmed. The Supreme Court granted Miles’s petition for a writ of certiorari to review the remedy ordered by the Court of Appeals for the trial court’s imprecise and incomplete analysis under Batson v. Kentucky, 476 U.S. 79 (1986). The Supreme Court found the Court of Appeals applied the appropriate remedy by remanding for the trial court to conduct a hearing to complete the second and third steps of the Batson analysis for three challenged venirepersons. Therefore, the judgment of the circuit court's judgment was affirmed in part, and the case was remanded. View "Miles v. Mississippi" on Justia Law

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Eugene Bullen was convicted of driving under the influence (DUI), second offense. He appealed to the County Court of Madison County. Following a bench trial, the trial judge found Bullen guilty and sentenced him to thirty days of imprisonment, a two year’s driver’s license suspension, an alcohol and drug assessment, six months supervised probation, eighteen months unsupervised probation, and eighty hours of community service within six months. Aggrieved by that decision, Bullen appealed to the Madison County Circuit Court. The circuit court held that the decision of the county court was supported by substantial evidence and was not manifestly wrong. Bullen then appealed to the Mississippi Supreme Court, arguing the trial court erred by not granting his motion to dismiss for insufficiency of the evidence. Bullen argued the State did not meet its burden to prove beyond a reasonable doubt that he was intoxicated. After review, the Supreme Court held the trial judge was presented with sufficient evidence to find Bullen guilty of violating Mississippi Code Section 63-11-30(1)(a), and accordingly, affirmed. View "Bullen v. Mississippi" on Justia Law

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In 2017, Shakeara Harris filed domestic violence charges against Joseph Eubanks. Eubanks was indicted for aggravated domestic violence in June 2017. He was later convicted of simple assault domestic violence in January 2020. Eubanks was sentenced to six months in the custody of the Mississippi Department of Corrections, with six months suspended and 364 days of unsupervised probation. He appealed, raising seven contentions as grounds for appeal. Finding no reversible error however, the Mississippi Supreme Court affirmed Eubanks' conviction. View "Eubanks v. Mississippi" on Justia Law

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The issue this case presented for the Mississippi Supreme Court's review centered on whether Allen Russell’s life sentence without the possibility of parole for possession of marijuana, as an habitual offender under Mississippi Code Section 99-19-83 (Rev. 2020), violates his Eighth Amendment right to be free from cruel and unusual punishment. The Court of Appeals stalemated five to five, resulting in an affirmance of the trial court's judgment. The Supreme Court affirmed: "Based on both this Court’s precedent and the rulings of the United States Supreme Court in Rummel, 445 U.S. 263, Harmelin, 501 U.S. 263, Andrade, 538 U.S. 63, and Ewing, 538 U.S. 11, Russell’s sentence as an habitual offender was not grossly disproportionate. His sentence meets the prescribed statutory punishment. There is no legal basis to vacate Russell’s sentence. It is neither cruel nor unusual. As Russell has failed to prove that the threshold requirement of gross disproportionality was offered and met, because his sentence fell within the statutory requirement, and because his sentence is a constitutionally permissible sentence, we should affirm Russell’s conviction and sentence." View "Allen v. Mississippi" on Justia Law

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Kendall Magee pled guilty to second-degree murder and possession of a firearm by a convicted felon. For his conviction of second-degree murder, Magee was sentenced to thirty-five years in the custody of the Mississippi Department of Corrections (MDOC), with ten years suspended and five years’ post-release supervision. For his conviction of possession of a firearm by a convicted felon, Magee was sentenced to ten years in the custody of the MDOC, with ten years suspended and five years’ post-release supervision. The sentences were ordered to run consecutively. In his motion for post-conviction relief, Magee claimed his guilty plea was involuntary because: (1) his attorney was ineffective and misrepresented the consequences of the plea and sentence; (2) his attorney was ineffective and failed to properly investigate his case; and (3) the circuit judge coerced him into pleading guilty. Regarding his misrepresentation claim, Magee asserted his trial counsel “advised [him] to take the plea because he would only serve six to seven years in prison.” According to Magee, after he entered his guilty plea, he learned that he was not eligible for early release and “that his actual time to serve in prison would be 25 years.” The Mississippi Supreme Court concluded Magee was entitled to a second evidentiary hearing about “whether Magee was misinformed as to the consequences of his pleas of guilty and whether those pleas were given in reliance on the alleged misinformation.” The circuit court's judgment was reversed and the matter remanded for further proceedings. View "Magee v. Mississippi" on Justia Law

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At issue in this interlocutory appeal was whether the circuit court had jurisdiction to hear defendant Rayvon Altman's case. In August 2020, Altman was indicted in on four counts of aggravated assault in violation of Mississippi Code Section 97-3-7(a)(1) (Rev. 2020). The indictment alleged that Altman intentionally drove his motor vehicle into another vehicle, which was occupied by four people, in an attempt to injure the occupants. It was subsequently acknowledged that the occupants of the other vehicle were Altman’s mother, siblings, and stepfather. In early 2021, Altman filed a motion to dismiss the indictment for lack of jurisdiction, arguing that the indictment should have been dismissed because the youth court had exclusive jurisdiction under Section 43-21-151 because he was under eighteen years of age at the time of the alleged offense. The Mississippi Supreme Court found both Altman and the State agreed that the deadly weapon exception was inapplicable because Section 97-37-1 did not prohibit the concealed carrying of an automobile. Thus, the circuit court did not have jurisdiction over Altman because he was a minor at the time the alleged offense was committed. The circuit court’s order was reversed and the case remanded to the circuit court for it to render a judgment dismissing Altman’s indictment and to “forward all documents pertaining to the cause to the youth court[.]” View "Altman v. Mississippi" on Justia Law