Justia Criminal Law Opinion Summaries

Brandy Williams was convicted by jury of the capital murder of Sheriff Garry Welford. He was sentenced to life without the possibility of parole. On appeal, Williams argued the trial court erred by not quashing her indictment, improperly instructing the jury and admitting evidence of her prior crimes. After review, the Mississippi Supreme Court found no reversible error and affirmed. View "Williams v. Mississippi" on Justia Law

Joseph Patrick Brown was convicted of capital murder and sentenced to death in 1994, and his conviction and sentence were affirmed by the Mississippi Supreme Court in 1996. Brown notified the Supreme Court of his intent to file a successive petition for post-conviction relief. Included in that notice was a motion requesting the Court to direct the Circuit Court of Adams County to assume jurisdiction over “discovery matters relevant to Mr. Brown’s successive post-conviction claims.” The Supreme Court unanimously denied that motion on December 17, 2015, finding that “there has been no minimal showing of any need for pre-petition discovery.” Brown’s Motion for Leave to Invoke Discovery and Seek Access Orders in the Circuit Court was thus denied. “The only thing differentiating this motion from the previous request is that Brown now presents [the Supreme] Court with several discovery ‘needs.’ Aside from references to a claim of ineffective assistance of post-conviction counsel, Brown’s motion does not identify with any particularity the issues that he plans to raise in his successive petition. Instead, he claims that so-called ‘pre-petition discovery’ is necessary for him to ‘file a meaningful and constitutionally adequate motion for leave to proceed in the trial court with a petition for post-conviction relief.’” View "Brown v. Mississippi" on Justia Law

Nicholas Johnson appealed his convictions of burglary and attempted armed robbery, claiming the State presented insufficient evidence to identify him as the perpetrator and that the jury found he was the perpetrator contrary to the overwhelming weight of the evidence. Because three witnesses identified Johnson with absolute certainty, the Mississippi Supreme Court affirmed. View "Johnson v. Mississippi" on Justia Law

Jafron Roberts was convicted by jury of kidnapping and statutory rape, but was acquitted him of sexual battery. The Circuit Court imposed the maximum penalty for the kidnapping conviction, thirty years, and sentenced Roberts to thirty-seven years for the statutory rape conviction, to run concurrently with his sentence for kidnapping. Roberts appealed, arguing: (1) the trial court should have granted his motion to suppress his statement to the police; (2) the trial court should have granted his request for production and in camera inspection of medical records; (3) the State’s loss of exculpatory evidence denied his right to due process; (4) the trial court should have excluded the testimony of the State’s DNA expert; and (5) a pre-indictment delay of approximately one year violated his due process rights. Finding no error, the Mississippi Supreme Court affirm Roberts’ convictions. View "Roberts v. Mississippi" on Justia Law

Kevin Boston was convicted of capital murder for the killing of Willie Dean. Boston raised five issues on appeal, one of which was raised by Boston himself in a pro se supplemental brief. In that supplemental brief, Boston argued the trial court erred by granting the State’s “pre-arming instruction.” Finding that the granting of the pre-arming instruction was reversible error, the Mississippi Supreme Court reversed Boston’s conviction and sentence and remanded the case for a new trial. View "Boston v. Mississippi" on Justia Law

Years after his direct appeal was affirmed by the Court of Appeals, Winfred Forkner filed a motion for postconviction relief. The circuit court denied the motion as untimely. Forkner appealed, and the Court of Appeals found that the circuit court was without authority to adjudicate the appeal because Forkner had not obtained the required permission from the Mississippi Supreme Court to file his motion for post-conviction relief in the circuit court. The Court of Appeals also held, erroneously, that the circuit court’s lack of authority to entertain the motion deprived the Court of Appeals of jurisdiction over the appeal. The Court of Appeals then dismissed the appeal, thus allowing the circuit court’s erroneous judgment to stand. The Supreme Court found that because the Court of Appeals did have jurisdiction to consider the lawfulness of the circuit court’s judgment, it erroneously dismissed Forkner’s appeal. Therefore, it reversed the Court of Appeals. Because the circuit court lacked authority to entertain Forkner’s motion, as the Court of Appeals rightly determined, the Supreme Court vacated the circuit court’s judgment. View "Forkner v. Mississippi" on Justia Law

William Ashwell pleaded guilty to burglary and escape. He sought postconviction relief. The Mississippi Supreme Court found, after review of his case, that the circuit court lacked jurisdiction and authority to accept guilty pleas when Ashwell never had been charged with a crime. Accordingly, the Court reversed and vacated Ashwell’s convictions. View "Ashwell v. Mississippi" on Justia Law

The circuit court ruled Enoch Oliver could proceed to trial with his malicious-prosecution claim against University of Mississippi Medical Center (UMMC) and two of its law-enforcement officers, Syrone McBeath and David Stewart. Oliver was charged with three misdemeanors: disorderly conduct for failure to comply with the commands of a police officer, resisting arrest, and carrying a concealed weapon. A nol-pros order was signed by the trial court and charges were ultimately dropped against Oliver. Oliver sued civilly, and UMMC, McBeath, and Stewart were served with process; several other officers were not. UMMC, McBeath, and Stewart filed a motion to dismiss, which was joined by the unserved defendants, who specially appeared. The served defendants argued Oliver’s claims were governed by the Mississippi Tort Claims Act (MTCA) and its one-year statute of limitations. The lone exception was the malicious prosecution of the felony claim, because the one-year statute of limitations did not begin to run until that charge was nol-prossed. The unserved defendants’ motion was granted, leaving the remaining claim against the served defendants as the malicious-prosecution claim based on the felony charge. Three-and-a-half years later, UMMC, McBeath, and Stewart filed a motion for summary judgment. UMMC argued, as a state agency, it had not waived sovereign immunity for a malice-based claim; McBeath and Stewart argued Oliver lacked proof they maliciously prosecuted him. Alternatively, all defendants cited the MTCA’s police-protection and discretionary-function immunity. The circuit court denied the defendants’ motion. UMMC, McBeath, and Stewart filed this interlocutory appeal, claiming they were entitled to summary judgment. The Mississippi Supreme Court determined as a matter of law, malice-based torts did not fall under the Mississippi Tort Claims Act’s sovereign-immunity waiver. So Oliver had no malicious-prosecution claim against UMMC or its employees in their official capacity. Oliver also brought malicious-prosecution claims against the UMMC officers in their individual capacity, but the record showed Oliver failed to put forth any evidence the officers acted with malice or lacked probable cause. The Court thus reversed the circuit court’s denial of summary judgment and rendered a final judgment in defendants’ favor. View "University of Mississippi Medical Center v. Oliver" on Justia Law

Groundworx,LLC, appealed a judgment dismissing its breach-of-contract action against the City of Hattiesburg. After reviewing the contract between Groundworx and the City, which Groundworx attached to its complaint, the Mississippi Supreme Court was left with “no doubt” that Groundworx’s complaint was properly dismissed for failure to state a claim. Even taking all of Groundworx’s allegations as true, Groundworx could cite no contractual provision the City allegedly breached. Even if Groundworx expended millions of dollars preparing to perform under the contract, it did so before securing the necessary financing to complete the project. And unfortunately for Groundworx, the contract was clear: if Groundworx did not secure financing by a certain date, the City had the right to terminate the contract. So the Court concluded Groundworx could prove no set of facts to show the City breached the contract. View "Groundworx, LLC v. City of Hattiesburg" on Justia Law

Trevioun Briggs was convicted for robbery and witness-tampering. The Court of Appeals affirmed both convictions. Briggs petitioned the Mississippi Supreme Court for certiorari, which was granted to consider whether his indictment for the witness-tampering count was defective. Finding that the indictment fairly tracked the language of Mississippi Code Section 97-9-115, the Court affirmed the judgment of the Court of Appeals. View "Briggs v. Mississippi" on Justia Law