Justia Criminal Law Opinion Summaries

Lucas Montel Howard, while detained in the Madison County jail, directed his friend Alissia Washington to purchase crack cocaine from a dealer. Law enforcement monitored their phone calls, and when Washington returned with the drugs, she was pulled over and instructed by Howard to hide the cocaine in her vagina. The drugs were later discovered during a search at the police department, leading to Howard and Washington’s indictment on felony drug charges. Washington entered a best-interest plea, while Howard went to trial and was found guilty of possession of cocaine with intent to sell and conspiracy to possess cocaine with intent to sell.The Madison County Circuit Court sentenced Howard as a nonviolent habitual offender and subsequent drug offender to sixty years for possession with intent to sell and twenty years for conspiracy, to run concurrently. Howard appealed, arguing insufficient evidence of intent to sell, a Confrontation Clause violation, double jeopardy, improper admission of Washington’s guilty plea, prosecutorial misconduct, ineffective assistance of counsel, and a sleeping juror issue.The Supreme Court of Mississippi reviewed the case and found that the evidence, including Howard’s phone calls and prior convictions, sufficiently supported the jury’s findings of intent to sell and conspiracy. The court held that the trial court did not abuse its discretion in limiting cross-examination or in handling the sleeping juror issue. The court also found no merit in Howard’s claims of double jeopardy, prosecutorial misconduct, or ineffective assistance of counsel. The cumulative error doctrine was deemed inapplicable as no errors were identified. Consequently, the Supreme Court of Mississippi affirmed Howard’s convictions and sentences. View "Howard v. State of Mississippi" on Justia Law

In the early morning of April 29, 2020, Davonta Wells went to his former girlfriend Taharika Smith's home and, after being denied entry, fired six shots into the residence. Wells was identified as the shooter by Smith, a guest named James Rice, and a neighbor, Pierre Beard. Wells was charged with shooting into an occupied dwelling and possession of a firearm by a convicted felon. He was tried by a jury in the Circuit Court of Lowndes County, Mississippi, and convicted on both counts. Wells was sentenced as a nonviolent habitual offender to ten years for shooting into an occupied dwelling and ten years with four years suspended for possession of a firearm by a convicted felon, to run consecutively.Wells appealed, arguing that the evidence was insufficient to support his conviction for possession of a firearm by a convicted felon because the stipulation of his prior felony was not formally admitted into evidence. The State contended that Wells waived this argument by not objecting at trial and that the stipulation, along with a limiting jury instruction, was sufficient.The Supreme Court of Mississippi reviewed the case and found that Wells was procedurally barred from raising the issue for the first time on appeal. The court also applied the invited error doctrine, noting that Wells had made a tactical decision to stipulate to his prior felony conviction and did not object at trial. The court declined to adopt Wells's proposed requirement for written stipulations to be admitted into evidence, affirming that the current law, which allows for stipulations to be presented through jury instructions, was sufficient. The court held that the stipulation and the limiting instruction provided to the jury met the evidentiary requirements, thus affirming Wells's conviction for possession of a firearm by a convicted felon. View "Wells v. State of Mississippi" on Justia Law

Laquon Fluker was convicted of conspiracy to commit aggravated assault. The incident involved Fluker and others allegedly attacking James Bryant in a prison cell, resulting in Bryant being stabbed. Fluker requested a jury instruction on the lesser-included offense of conspiracy to commit simple assault, which the trial court denied. The jury found Fluker not guilty of aggravated assault but guilty of conspiracy to commit aggravated assault.The Forrest County Circuit Court denied Fluker's request for the lesser-included-offense instruction. The Court of Appeals affirmed this decision, reasoning that the presence of shanks and the nature of the attack indicated an intent to commit aggravated assault. The appellate court held that the evidence did not support a finding of negligence, which would be necessary for a simple assault instruction.The Supreme Court of Mississippi reviewed the case on certiorari. The court found that the trial court erred in denying the lesser-included-offense instruction. The Supreme Court held that, based on the testimony of a co-conspirator, a reasonable jury could have found Fluker guilty of conspiracy to commit simple assault rather than aggravated assault. The court emphasized that the jury should have been allowed to consider whether the agreement among the conspirators was to commit simple assault. Consequently, the Supreme Court reversed the judgments of the Court of Appeals and the Forrest County Circuit Court and remanded the case for a new trial. View "Fluker v. State" on Justia Law

In 1998, Michael Johnson, then 17, conspired with Aaron Johnson to murder Aaron’s roommate, Dustin Sean Parker. They planned the murder for hours, eventually deciding to bludgeon Parker to death with a metal barbell. After killing Parker, they wrapped his body in plastic bags and buried it in the woods. Johnson later bragged about the murder, leading to his arrest and conviction for deliberate-design murder. He was sentenced to life in prison without the possibility of parole.The Rankin County Circuit Court initially sentenced Johnson to life without parole. Following the U.S. Supreme Court's decision in Miller v. Alabama, which deemed mandatory life-without-parole sentences for juveniles unconstitutional, Johnson sought post-conviction relief. The trial court vacated his sentence and held a new hearing, considering the Miller factors. Despite this, the court reinstated Johnson’s life sentence, ruling that the parole statute's application was not unconstitutional.The Supreme Court of Mississippi reviewed the case. Johnson argued that the trial court misapplied the law and facts and that Mississippi Code Section 99-19-101 required jury sentencing for juveniles. The court found that recent statutory amendments did not entitle Johnson to jury sentencing, as he was convicted before July 1, 2024. The court also upheld the trial court's application of the Miller factors, noting Johnson’s age, the premeditated nature of the crime, and the lack of evidence suggesting his immaturity or inability to understand the consequences of his actions. The court affirmed the trial court’s decision, maintaining Johnson’s life sentence without parole. View "Johnson v. State" on Justia Law

Derrick Chatman was convicted of two counts of sexual battery by a jury in the Adams County Circuit Court. The jury was also instructed on the lesser-included offense of gratification of lust for both counts. Chatman appealed, arguing that the jury’s verdict was ambiguous and not fully responsive to the verdict forms, which included the lesser-included offense. He claimed the trial court erred by not directing the jury to retire for further deliberations.The Adams County Circuit Court sentenced Chatman to thirty years for each count, with fifteen years suspended and fifteen years to serve consecutively. Chatman filed a motion for judgment notwithstanding the verdict or, alternatively, for a new trial, which the trial court denied. On appeal, Chatman raised the issue of the ambiguous verdict for the first time, arguing that the trial court should have directed the jury to deliberate further under Mississippi Rule of Criminal Procedure 24.3.The Supreme Court of Mississippi reviewed the case and agreed that the jury’s verdict was ambiguous regarding the sexual battery charges. The court found that the trial court should have directed the jury to retire for further deliberations. The court noted that the jury’s general verdicts of guilty did not clarify whether they found Chatman guilty of sexual battery or the lesser-included offense of gratification of lust. Consequently, the court reversed Chatman’s convictions for sexual battery.The Supreme Court of Mississippi reversed and remanded the case for either a new trial on the sexual battery charges or for resentencing on two counts of gratification of lust, at the option of the State. The court emphasized that the ambiguity in the jury’s verdict required this remedy to ensure a fair and just outcome. View "Chatman v. State of Mississippi" on Justia Law

Soweto Ronnell Love pled guilty to two counts of attempting to acquire or obtain possession of a controlled substance by forged prescription and was sentenced as a habitual offender to five years on each count, to run consecutively. Love later filed a pro se Motion for Post-Conviction Collateral Relief (PCR), challenging the voluntariness of his guilty plea. The Tate County Circuit Court dismissed his PCR motion without an evidentiary hearing, finding that Love's plea was voluntary based on the record.On appeal, the Mississippi Court of Appeals affirmed the circuit court's dismissal of Love's PCR motion in a divided decision. The Court of Appeals held that a factual basis existed for Love's plea and that he failed to show his plea was involuntary. Love then filed a pro se motion for rehearing, which was denied, and subsequently filed a petition for writ of certiorari, which the Supreme Court of Mississippi granted.The Supreme Court of Mississippi found that the circuit court erred in dismissing Love's PCR motion without an evidentiary hearing. The court held that Love was misinformed about the minimum penalty he faced as a habitual offender, which amounted to a misapplication of the law and plain error. The court also found that the record did not confirm that Love knowingly pled guilty as a habitual offender. Consequently, the Supreme Court reversed the circuit court's dismissal of Love's PCR motion and the Court of Appeals' decision, remanding the case to the circuit court for an evidentiary hearing to determine whether Love voluntarily pled guilty as a habitual offender. View "Love v. State of Mississippi" on Justia Law

Jatavis Williams was indicted for first-degree murder after the shooting death of Tacari Walker. On November 9, 2020, police responded to a shooting in Columbus, Mississippi, where they found Walker unresponsive. Witnesses indicated that Williams and Walker had been arguing prior to the incident. Williams turned himself in the next day. At trial, Williams claimed self-defense, stating that Walker had threatened him and approached his vehicle aggressively. However, an eyewitness testified that Walker was unarmed and appeared happy before the shooting.The Lowndes County Circuit Court conducted a jury trial from August 22 to August 26, 2022. The jury found Williams guilty of first-degree murder, and he was sentenced to life imprisonment. Williams filed a motion for judgment notwithstanding the verdict or a new trial, which the trial court denied. He then appealed, arguing that the conviction was against the overwhelming weight of the evidence and that the trial court erred in denying his request for a mistrial due to disruptions during the trial.The Supreme Court of Mississippi reviewed the case and affirmed the lower court's decision. The court held that the trial court did not abuse its discretion in denying the mistrial. The disruptions, including an outburst from the victim’s mother and an inappropriate video during a witness's Zoom testimony, were addressed by polling the jury, who indicated they could remain impartial. The court also found that the jury's verdict was not against the overwhelming weight of the evidence, as the jury had properly considered the self-defense claim and found it unconvincing. Therefore, the conviction and sentence were upheld. View "Williams v. State of Mississippi" on Justia Law

On March 7, 2018, a ninth grader named Becky was kidnapped at gunpoint by Jimmy David Williams, a friend of her stepfather, while she was on her way to school. Williams forced Becky into his vehicle, drove to a secluded area, and sexually assaulted her. After the assault, Williams dropped Becky off at school, where she immediately reported the incident to her JROTC instructor. Becky was taken to a hospital for a sexual assault examination, which revealed physical evidence consistent with her account. DNA evidence linked Williams to the crime.The Jackson County Circuit Court convicted Williams of sexual battery and sentenced him to thirty years in prison without the possibility of parole. Williams filed a motion for a new trial or a judgment notwithstanding the verdict, arguing that the conviction was against the overwhelming weight of the evidence due to conflicting testimony. The trial court denied his motion, leading to Williams's appeal.The Supreme Court of Mississippi reviewed the case and upheld the trial court's decision. The court found that the jury had appropriately resolved the conflicting testimonies, including a statement from a social worker suggesting Becky had been gang-raped by multiple men, which Becky denied. The court emphasized that the jury's role is to assess the credibility of witnesses and weigh the evidence. Given the substantial evidence supporting the conviction, including immediate reports by Becky and corroborating DNA evidence, the court concluded that the verdict was not against the overwhelming weight of the evidence. Therefore, the trial court did not abuse its discretion in denying Williams's motion for a new trial. The Supreme Court of Mississippi affirmed Williams's conviction and sentence. View "Williams v. State of Mississippi" on Justia Law

In 2023, Christopher Sheely was convicted for possessing more than one-tenth gram but less than two grams of methamphetamine. He was sentenced to two years in the custody of the Mississippi Department of Corrections, with the remainder suspended for post-release supervision upon completing a drug and alcohol program. Sheely appealed, arguing that the trial court erred by denying his proposed broken chain of custody jury instruction and that the evidence was insufficient to support the jury’s verdict.The Forrest County Circuit Court initially handled the case, where Sheely was found guilty by a jury. Sheely moved for a directed verdict and later for a judgment notwithstanding the verdict or a new trial, both of which were denied by the trial judge. The trial court found that an adequate chain of custody had been established and that Sheely failed to produce evidence of tampering or substitution of the evidence.The Supreme Court of Mississippi reviewed the case. The court held that the evidence was sufficient to support the jury’s verdict that Sheely knowingly possessed a felony amount of methamphetamine. The court found that the jury was presented with enough evidence to conclude that Sheely was aware of the presence and character of the methamphetamine and that it weighed more than one-tenth of a gram. Additionally, the court held that the trial court did not abuse its discretion in refusing Sheely’s proposed chain of custody jury instruction, as Sheely failed to present evidence of probable tampering or substitution. The Supreme Court of Mississippi affirmed the lower court’s decision. View "Sheely v. State of Mississippi" on Justia Law

On September 7, 2019, Kemond Jones shot Ethan Powell eight times with a 9 mm handgun in the Beechwood Estates neighborhood in Warren County. Powell died from his injuries later that morning. Witness Danny Guice identified Jones as the shooter, and Jones turned himself in later that day. At trial, Guice testified about a prior disagreement between Jones and Powell, and forensic evidence confirmed the cause of death. Jones claimed self-defense, stating Powell slapped him and reached for a gun before he shot him.The Warren County Circuit Court convicted Jones of murder and sentenced him to forty years, with ten years suspended. Jones's motion for a judgment notwithstanding the verdict or a new trial was denied. He appealed, arguing that the trial court erred by allowing improper evidence and that the verdict was against the overwhelming weight of the evidence.The Supreme Court of Mississippi reviewed the case and affirmed the lower court's decision. The court held that the prosecutor's statement during the opening was not evidence and did not prejudice the jury. Additionally, the court found that the jury's verdict was supported by sufficient evidence, including eyewitness testimony from Guice. The court also determined that the Weathersby rule, which requires the acceptance of the defendant's version of events if they are the only eyewitnesses, did not apply because there was conflicting eyewitness testimony from the prosecution. The court concluded that the trial court did not commit reversible error and upheld the conviction and sentence. View "Jones v. State of Mississippi" on Justia Law