Justia Criminal Law Opinion Summaries

In this case, law enforcement responded to a 2017 homicide in which the victim was found shot in the head, with evidence suggesting robbery and drug involvement. The investigation initially stalled due to lack of leads, but in 2019, new information led to the identification of three suspects, including the appellant. The case remained unresolved until 2021, when the appellant was arrested on unrelated charges and questioned about the murder. During two recorded interviews, the appellant first denied involvement but later admitted to being present and participating in a plan to rob the victim. Other suspects were also interviewed, and ultimately, the appellant and three others were indicted for capital murder. Two co-defendants pleaded guilty to lesser charges, and another pleaded guilty to murder.The case was tried in the Alcorn County Circuit Court. The appellant moved to suppress his statements from both interviews, arguing they were involuntary due to intoxication and coercion, and that his right to counsel was violated. The trial court denied the motion after a suppression hearing, finding the statements voluntary and the right to counsel not unequivocally invoked. At trial, the appellant’s statements and testimony from co-defendants were admitted. The jury convicted the appellant of capital murder, and he was sentenced to life without parole. Post-trial motions for judgment notwithstanding the verdict or a new trial were denied.On appeal, the Supreme Court of Mississippi reviewed claims regarding the denial of the suppression motion, alleged improper witness vouching, the admission of a co-defendant’s prior statement, and ineffective assistance of counsel. The court held that the trial court did not abuse its discretion in admitting the appellant’s statements, found no reversible error in the handling of witness testimony, and determined that any procedural errors were either barred or did not amount to ineffective assistance. The conviction and sentence were affirmed. View "Reyes v. State" on Justia Law

After being suspended from his long-term employment at a Walmart in Southaven, Mississippi, following an incident involving a coworker, the defendant planned and executed a violent attack targeting those he blamed for his suspension. Three days after the suspension, he shot and killed two Walmart managers, set fire to the store, and, during his attempted escape, shot a responding police officer. Surveillance footage captured the events, and the defendant admitted to the killings, arson, and shooting the officer during trial.A jury in the Circuit Court of DeSoto County convicted the defendant of two counts of capital murder and one count of attempted murder. The jury sentenced him to death for each capital murder conviction and to life imprisonment for the attempted murder. The defendant moved for judgment notwithstanding the verdict, which the circuit court denied.On direct appeal, the Supreme Court of Mississippi reviewed several claims: that the trial court erred in admitting evidence from locations other than the crime scene; that the evidence was insufficient to support the capital murder convictions because the arson and murders were not part of one continuous transaction; that the verdicts were against the overwhelming weight of the evidence; and that the court should abandon the M’Naghten Rule as the standard for insanity. The Supreme Court found no error in the admission of evidence, held that the evidence was sufficient to support the convictions under the one-continuous-transaction doctrine, determined the verdicts were not against the overwhelming weight of the evidence, and declined to abandon the M’Naghten Rule. The court also found the death sentences were not disproportionate. Accordingly, the Supreme Court of Mississippi affirmed the convictions and sentences. View "Abram v. State" on Justia Law

Jonathan Harrelson was convicted of statutory rape and sentenced to forty years in the custody of the Mississippi Department of Corrections. The incident involved Harrelson, who was forty-four, picking up two minors, Kendall and Valerie, and taking them to various locations, including a motel and a resort. Kendall testified that Harrelson had sexual intercourse with her at the motel, while Harrelson denied any sexual contact and claimed he believed the girls were older.The case was initially tried in the Jones County Circuit Court, where a jury found Harrelson guilty of statutory rape. Harrelson was sentenced to forty years and required to register as a sex offender. He filed a motion for a new trial, which was denied, leading to this appeal.The Supreme Court of Mississippi reviewed the case. Harrelson argued that prosecutorial misconduct deprived him of a fair trial and that the verdict was against the weight of the evidence. The court found that although the prosecutor's comments about the absence of certain witnesses were improper, Harrelson did not suffer prejudice due to the substantial evidence of his guilt. The court also determined that the weight of the evidence supported the jury's verdict, noting that the testimony of the victim, Kendall, was corroborated by other evidence and that issues of credibility were for the jury to decide.The Supreme Court of Mississippi affirmed Harrelson's conviction and sentence, concluding that the trial was fair and the evidence supported the jury's decision. View "Harrelson v. State of Mississippi" on Justia Law

A man was accused of attempting to commit statutory rape against his thirteen-year-old stepdaughter. The incident occurred in the early morning hours when the child’s mother discovered the man in bed with her daughter, who was nude except for a bra. The mother called 911, and the child was taken to the hospital and later interviewed at a Children’s Advocacy Center. The man was initially indicted on seven counts related to various alleged acts against the child, but all but one count—attempted statutory rape—were dropped or not presented to the jury at trial.The case was tried in the Warren County Circuit Court. Before trial, the court held a hearing to determine whether the child’s recorded interview at the advocacy center could be admitted under the tender years hearsay exception. The court allowed the recording, finding the exception satisfied. During trial, the court also admitted a 911 dispatch report over defense objections regarding hearsay and reliability. The jury heard testimony from the child, her mother, law enforcement, a forensic interviewer, and a nurse examiner. The defense challenged the credibility of the evidence and witnesses, but the jury found the defendant guilty of attempted statutory rape. The trial court sentenced him to fifty years in prison, with thirty years to serve.On appeal, the Supreme Court of Mississippi reviewed claims that the admission of the child’s interview and the 911 report were erroneous, that expert and prosecutorial comments improperly vouched for the child’s credibility, and that cumulative error deprived the defendant of a fair trial. The court held that no reversible error occurred, finding that the defendant’s confrontation rights were not violated, the evidentiary rulings were not plain error, and there was no improper vouching or cumulative error. The conviction was affirmed. View "Cole v. State of Mississippi" on Justia Law

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