Justia Criminal Law Opinion Summaries

In this case, the Supreme Court of Mississippi heard an appeal by Christopher Stewart who was convicted on two counts of sexual battery against his two preteen nieces. Stewart argued that he was entitled to a new trial because he was not physically present at a pretrial tender-years hearing due to COVID-19 restrictions and also claimed that the evidence presented was insufficient. The court affirmed both convictions and sentences. It held that Stewart's virtual attendance at the hearing due to the COVID-19 pandemic did not constitute reversible error as he was able to cross-examine the witnesses at the trial where he was physically present. The court referred to a similar case (Kentucky v. Stincer) where the Supreme Court found no Confrontation Clause or due-process violation for a defendant's exclusion from a pretrial hearing. As for the sufficiency of the evidence, the court rejected Stewart's claim that the State had to prove all three methods of penetration (vaginal, anal, and oral) as charged in the indictment. The court found that there was evidence of all three types of penetration and, in any case, the State only needed to prove one form of penetration to establish the offense of sexual battery. View "Christopher Stewart v. State of Mississippi" on Justia Law

The Supreme Court of Mississippi reviewed the case of Jameco Davis and Jacqlaurence Jackson, who were convicted of two counts of first-degree murder. Both men contested their convictions and sentences. They argued that the trial court made errors in adding a firearm enhancement to their sentences, in failing to follow proper procedures to review a Batson challenge (a challenge against racial bias in jury selection), and that the verdict was against the overwhelming weight of the evidence. Jackson additionally argued that the evidence was insufficient to support the verdict, that the trial court erred in denying his motion to sever and have separate trials, and that the cumulative effect of these errors denied him a fair trial.The Supreme Court found that the firearm enhancement portions of the sentences should be vacated, as the sentence for first-degree murder, life in prison, was greater than the five years provided for in the firearm enhancement statute. The court disagreed with the remaining arguments, stating that the trial court's failure to follow proper procedures for a Batson challenge was not clearly erroneous and did not prejudice the defendants, and there was no evidence to support the claim that the trial court's cumulative errors denied Jackson a fair trial. The court also found that the evidence was enough to support the verdict. The court thus vacated the firearm enhancement portions of the sentences, and affirmed the remaining convictions and sentences. View "Davis v. State of Mississippi" on Justia Law

In this criminal case heard by the Supreme Court of Mississippi, Willie Douglas was convicted and sentenced to life imprisonment as a habitual offender for two counts of sale of less than two grams of cocaine. The cocaine was sold to a confidential informant, Ronald Keen, during two controlled purchases that were orchestrated and monitored by law enforcement officers from the Batesville Police Department. The substances bought during these controlled purchases were tested and confirmed to be cocaine by the Mississippi Forensics Laboratory.On appeal, Douglas raised multiple issues, including an illegal sentence, improper indictment, denial of the right to self-representation, bias of the trial judge, and credibility of witnesses, among others. The Supreme Court of Mississippi found all his claims to be without merit. It held that there was no violation of Douglas's constitutional rights and the evidence presented at trial was sufficient to uphold the jury's verdict. The court affirmed the conviction and life sentence. View "Douglas v. State of Mississippi" on Justia Law

Timothy Robert Ronk, who was convicted of armed robbery and capital murder and sentenced to death, sought post-conviction relief for a second time. He claimed his post-conviction counsel was ineffective. The State of Mississippi, in response, requested an overruling of Grayson v. State, which held that ineffective-assistance-of-post-conviction-counsel claims are an exception to the bars in the Mississippi Uniform Post-Conviction Collateral Relief Act (UPCCRA). The Supreme Court of Mississippi agreed with the State, citing a recent decision (Howell v. State) which invalidated all cases in which Mississippi courts had applied a "judicially crafted fundamental-rights exception" to the UPCCRA’s bars. Therefore, the court partially overruled Grayson and denied Ronk's request for post-conviction relief. The court determined that Ronk's claims, including that his trial counsel failed to investigate his case thoroughly and that the State suppressed evidence, lacked arguable basis, were insufficient to overcome the statutory bars, and did not meet the "newly-discovered-evidence" exception. View "Ronk v. State of Mississippi" on Justia Law

In the case at hand, the Supreme Court of Mississippi dealt with an appeal by George Hawkins who was convicted for sexual battery of a minor under Mississippi Code Section 97-3-95(2). This law requires the State to prove that the defendant was in a position of trust or authority over the minor when the crime was committed. Hawkins' appeal was based on the argument that the State failed to present sufficient evidence of him being in such a position over the victim, as he had no legal authority over her.In 2014, Hawkins began dating Tonya Ingram and gradually became a part of her and her children’s lives, to the point where they even considered themselves to be common-law married. In the spring of 2015, Tonya and her children moved into Hawkins's home "as a family". Hawkins and Tonya filed their taxes jointly, claimed Tonya’s children as dependents, and contributed equally to the family’s finances. The victim, Jane, one of Tonya's children, trusted Hawkins, which ended when he sexually assaulted her one night.The court found that while Hawkins did not possess any legal authority over Jane, a reasonable jury could have concluded that he was in a position of trust or authority over her based on the totality of the circumstances and their relationship. The court held that the list of individuals who are typically in positions of authority provided in Section 97-3-95(2) serves only as examples, and does not limit this to persons in positions of legal authority over the child. Therefore, the court affirmed Hawkins' conviction. View "Hawkins v. State of Mississippi" on Justia Law

In this criminal case, the Supreme Court of Mississippi upheld the conviction of the defendant, Adam Mills, for first-degree murder. The case stemmed from Mills brutally killing his girlfriend while allegedly under the influence of drugs. Mills appealed his conviction, arguing that he could not be convicted of first-degree murder because the evidence did not support a finding that he had the requisite mental capacity to form a premeditated intent to kill. Mills also contended that the trial court erred by admitting photographs and body camera footage from the crime scene.The Supreme Court held that the trial court did not abuse its discretion by admitting the photographs and body camera footage. It reasoned that the materials served a useful evidentiary purpose by providing the jury with visual evidence of the crime scene and the victim’s injuries, which could aid in determining Mills's intent. Regarding the defendant's argument about his mental capacity, the Court ruled that voluntary intoxication is not a defense to a specific-intent crime such as first-degree murder. The Court held that the extent and nature of the victim's injuries, inflicted by Mills, were indicative of a deliberate design to kill.Therefore, the Court affirmed Mills's conviction and life sentence for first-degree murder. View "Mills v. State of Mississippi" on Justia Law

In 2004, De’Andre Dampier was convicted of a capital murder committed during an auto-dealership robbery when he was 16 years old. He was sentenced to life in prison without parole, which was the only statutory sentence available at the time. In 2012, the United States Supreme Court ruled that imposing mandatory life-without-parole sentences on juveniles violates the Eighth Amendment. Based on this ruling, the Supreme Court of Mississippi granted Dampier’s request to seek post-conviction relief from his life-without-parole sentence. However, before the trial court addressed any of the factors from the US Supreme Court decision, it vacated Dampier’s life-without-parole sentence. Dampier then requested that a jury be convened to decide if he should be sentenced to life with or without parole, but the trial judge denied this request. After a hearing in which the trial judge considered the factors from the US Supreme Court decision, the judge reimposed a sentence of life in prison without parole.The Supreme Court of Mississippi affirmed the decisions of the lower courts, holding that Dampier did not have a statutory right to be sentenced by a jury. The court emphasized that the decision to be made by the trial court was whether Dampier was entitled to post-conviction relief from his life-without-parole sentence, imposed for a crime committed when he was a juvenile. The court also agreed with the lower courts that the trial judge did not err by denying Dampier’s request for jury sentencing. Furthermore, the court agreed with the lower courts that the trial court did not err by ruling that, after a careful consideration of the factors from the US Supreme Court decision, life without parole was an appropriate sentence for Dampier’s crime. View "Dampier v. State of Mississippi" on Justia Law

In the Supreme Court of Mississippi, Isaiah Gunn was convicted of first degree murder, attempted murder, aggravated assault, and shooting into a dwelling. He was sentenced to life, forty years, twenty years, and ten years respectively. Gunn contested his conviction on appeal, arguing that the jury was improperly instructed and that the State did not present sufficient evidence to support his convictions, as he believed he acted in self-defense. The Supreme Court of Mississippi affirmed Gunn’s convictions on all counts.Gunn was indicted for these charges following an incident at his ex-girlfriend's residence where he shot and killed her and attempted to kill another man present at the scene. Gunn argued that he acted in self-defense after his ex-girlfriend pointed a shotgun at him, but the jury rejected this argument. The court found that the jury had been properly instructed on the law relating to self-defense and deliberate design, and held that the verdict was not against the overwhelming weight of the evidence.In terms of the alleged improper jury instruction, the court noted that the instruction given allowed the jury to infer deliberate design to kill if they found that Gunn intentionally used a deadly weapon to kill the victim. The court found this instruction to be permissible, as it only allowed the jury to reach a conclusion if the presented evidence supported that conclusion. Furthermore, the court concluded that the verdict was not contrary to the overwhelming weight of the evidence, as the jury could have concluded from the evidence that Gunn was not in any imminent danger, but instead was the aggressor in the situation. View "Gunn v. Mississippi" on Justia Law

In February 2003, Devin Bennett was found guilty of capital murder, and a jury sentenced him to death. The Mississippi Supreme Court affirmed Bennett’s conviction and sentence on appeal. In 2006, Bennett sought leave from the Court to file a motion for post-conviction relief. The Supreme Court ultimately determined that Bennett was entitled to seek post-conviction relief on his claim of ineffective assistance of counsel during the penalty phase of his trial. Bennett filed his PCR petition on October 1, 2008, and an amended petition on May 16, 2012. On March 25, 2021, the circuit court held an evidentiary hearing, and it ultimately denied Bennett’s amended petition. Bennett appealed again, but the Supreme Court upheld the denial: "while counsel might be faulted for not more thoroughly investigating the alternative mitigation case Bennett presented at the PCR hearing, we cannot find any reasonable probability that doing so would have led to a different outcome. In fact, although Bennett had fifteen years to assemble an alternative mitigation case, we agree with the trial judge that the additional evidence would have hurt Bennett more than it helped him." View "Bennett v. Mississippi" on Justia Law

Nathan Lollis and his codefendants, Marcel Smith and Charles Wells, were convicted by jury of first degree murder and conspiracy to commit murder. Lollis received a life sentence for murder and twenty years for conspiracy to commit murder. The trial court denied Lollis’s motion for judgment notwithstanding the verdict or, in the alternative, a new trial. He appealed, raising sufficiency of the evidence as the sole issue on appeal. Finding no error, the Mississippi Supreme Court affirmed. View "Lollis v. Mississippi" on Justia Law