Justia Constitutional Law Opinion Summaries

The issue before the Supreme Court in this breach of contract case was whether the appellate court erred in affirming the trial court's refusal to submit an issue of punitive damages to the jury. Finding that the plaintiff presented clear and convincing evidence that the defendant exhibited bad faith in breaching the contract, the Supreme Court reversed the Court of Appeals and remanded the case back to the trial court for the jury to determine what punitive damages, if any, were due. View "T.C.B. Construction Company, Inc. v. W. C. Fore Trucking, Inc." on Justia Law

The issue before the Supreme Court in this case was the circuit court's denial of a motion to compel arbitration. Nutt & McAlister, PLLC; David Nutt & Associates, PC; David H. Nutt; and Mary Krichbaum McAlister (“Nutt, et al.”) sought to enforce the mandatory arbitration provision in a contract titled “In Re: Katrina Litigation Joint Venture Agreement” (“Katrina JVA”). In a prior appeal, the Supreme Court settled the issue as to whether Appellee Wyatt’s claims were related to the Katrina JVA. The sole issue for determination then was whether the trial court erred by finding that Nutt, et al., waived their right to enforce the provision. Upon review, the Court concluded that Nutt, et al., did not waive their right to compel arbitration. The Court reversed the judgment of the trial court and remanded this case with instructions to refer Wyatt’s claims to arbitration. View "Nutt v. Wyatt" on Justia Law

In this Mississippi Tort Claims Act (MTCA) case, the issue before the Supreme Court was whether the circuit court erred in finding the City of Jackson (the City) liable for the death of Tawanda Sandifer. Tawanda Sandifer was a chronic runaway. Tawanda’s mother, Mildred Sandifer, testified at trial that Tawanda began running away from home for extended periods of time. Tawanda ran away approximately seventeen times before she ran away for the last time in April 2005. Mildred testified that she had filed a runaway petition for Tawanda every time she had run away, and that Jackson Police Department (JPD) had taken Tawanda into custody on a few occasions. In 2006, approximately nine months after running away, a then fifteen-year-old Tawanda died as a result of blunt-force trauma after being beaten by her boyfriend, Toice Wilson. Tawanda’s parents, on behalf of her wrongful-death beneficiaries, filed suit against the City of Jackson and several police officers, in their official and individual capacities, for, among other claims, the wrongful death of Tawanda. The Sandifers alleged that the City caused or contributed to Tawanda’s death by ignoring its own policies with regard to runaways; by failing to investigate Tawanda’s claims in 2004 that she was having sex with a JPD officer; by negligently failing to train, hire, supervise, instruct, monitor or control its employees; by failing to maintain an adequate system to hire, train, supervise, instruct, monitor, and/or control its employees; by allowing Tawanda to be subjected to assault, battery, physical, mental, and sexual abuse; and by failing to timely apprehend Tawanda and deliver her to her parents and other appropriate agencies despite knowledge of her status as a runaway. The circuit court ultimately concluded that the City’s failure to fully investigate Tawanda’s case “caused [Tawanda] to succumb to the brutal and fatal actions of Toice Wilson” and that Wilson and the City were jointly responsible for Tawanda’s death. The circuit court assessed damages in the amount of $1 million. The City then appealed. Upon review, the Supreme Court found that the City was immune from liability for the alleged misconduct of its employees at issue in this case under the Mississippi Tort Claims Act. Therefore, the Court reversed the judgment of the circuit court. View "City of Jackson, Mississippi v. Sandifer, Jr." on Justia Law

In 2010, Edward Daniels was indicted for burglary of a dwelling. The indictment alleged that he broke and entered a dwelling with the intent to commit grand larceny. Later, the State amended the indictment to charge Daniels as a habitual offender under Mississippi Code Section 99-19-83. The trial court granted the amendment and the case went to trial. Because Daniels did not appear for trial, the case was tried in his absence. The jury found Daniels guilty, and the court delayed sentencing until Daniels could be located. The court ultimately sentenced Daniels to life without the possibility of parole under Section 99-19-83. Daniels subsequently filed a motion for a new trial or judgment notwithstanding the verdict (JNOV), which the trial court denied. Daniels appealed his conviction. Upon review, the Supreme Court reversed the decision of the trial court denying Daniels's motion for new trial and remanded the case for further proceedings, because the jury instruction on the elements of burglary "was fatally flawed." View "Daniels v. Mississippi" on Justia Law

In 2000, Jay McCalpin pled guilty to one count of fondling and two counts of sexual battery involving a child under the age of fourteen and was sentenced to serve a term of fifteen years in the custody of the Mississippi Department of Corrections (MDOC), with ten years of his sentence suspended, and five years of post-release supervision upon his release from incarceration. In 2005, the circuit court revoked McCalpin's post-release supervision for the first time due to his failure to reside at the residence given to his supervising officer, failure to notify his supervising officer of at least three changes of residence, and failure of a drug test for marijuana. At that time, the circuit court judge revoked McCalpin's suspended ten-year sentence, ordering McCalpin to serve three years in the custody of the MDOC with seven years to remain suspended, conditioned upon McCalpin's "good behavior and that he does not violate any laws upon his release from custody." After his second release from incarceration, McCalpin's post-release supervision was revoked for a second time. McCalpin filed a motion for post-conviction relief (PCR) which was denied. He appealed the denial of his motion for PCR; the Court of Appeals affirmed. Upon review, the Supreme Court found that McCalpin did not comply with the rules of appellate procedure in seeking rehearing before the Court of Appeals. Therefore, the Court affirmed the appellate court's dismissal of McCalpin's motion for rehearing. View "McCalpin v. Mississippi" on Justia Law

Donald Mitchell directly appealed his conviction for possession of cocaine with the intent to distribute and his habitual-offender sentence to the Supreme Court. Finding that the trial court erred by admitting evidence of Mitchell's prior convictions for possession of marijuana and cocaine, the Court reversed Mitchell's conviction, vacated his sentence, and remanded for a new trial. View "Mitchell v. Mississippi" on Justia Law

An incident occurred at West Lauderdale High School which led to the suspension and eventual expulsion of four male students. The principal notified the four students' parents and/or guardians of the immediate suspension. (The four male students were identified herein as C.D., E.F., G.H., and I.J.) The matter was pending before the school board, and if the board approved the recommendation, the students could request a hearing before the school board to continue the suspension until such hearing occurred. Three of the four students, E.F., C.D., and G.H., requested a hearing. Prior to the disciplinary hearing, parents of E.F. and C.D. applied for separate ex parte temporary restraining orders (TROs) in the Lauderdale County Youth Court. The ex parte temporary restraining orders were granted without notice ordering that E.F. and C.D. be allowed to return to school and enjoining the superintendent and school board from expelling them or assigning them to an alternative school. At the hearing for the TROs, the school district objected to reenrollment because the youth court lacked jurisdiction to order the students' return to school. Nonetheless, the court ordered the reenrollment. After a hearing, the school board expelled all four students for one calendar year on the basis that their presence in school was a safety concern for other students. C.D. and E.F., through counsel, moved the youth court for reenrollment. The youth court granted this motion and treated it as an appeal on the record of the expulsion and "not a matter de novo." The school board timely appealed the youth court's decision to the Supreme Court and moved the youth court to stay its judgment pending appeal. Upon review, the Supreme Court concluded the youth court exceeded its statutory authority by reenrolling C.D. and E.F. in high school because the discretion in this situation lied with the school board. Accordingly, the Court reversed the youth court's decision and remanded the case for further proceedings. View "Lauderdale County School Bd. v. Brown" on Justia Law

After the trial judge granted the defendants summary judgment, the Supreme Court reversed and remanded the case for trial. More than four years later, the trial judge, finding the plaintiff had failed to prosecute his claim, entered a final judgment as to all defendants. Because the Court was unable to say the trial judge abused his discretion, affirmed. View "Hanson, Jr. v. Disotell" on Justia Law

Dante Lamar Evans was convicted of the murder of his father and sentenced as an adult to a mandatory term of life imprisonment. Evans petitioned the Supreme Court for a writ of certiorari, raising six issues: (1) whether the trial court erroneously refused to permit the jury to consider Evans's theory of imperfect self-defense; (2) whether the trial court erred in excluding testimony concerning Darold Evans's alleged abuse of Evans and his mother; (3) whether the trial court erred in refusing funds to hire a post-traumatic stress-disorder (PTSD) expert; (4) whether the trial court improperly prohibited the jury from considering Evans's age in its deliberations; (5) whether the trial court erred in admitting Evans's statements made to security guards and law-enforcement officers; and (6) whether Evans's life sentence was unconstitutional. Upon review, the Supreme Court found find that Evans demonstrated an actual need for an expert on PTSD. Therefore, the trial court abused its discretion in denying funds to hire such an expert. The Court reversed the judgment of both the Court of Appeals and the trial court and remanded for a new trial. View "Evans v. Mississippi" on Justia Law

Marcus O'Neal Flowers a/k/a Tupac a/k/a Marcus Flowers was convicted of murder for fatally shooting Charles Wash. He claimed on appeal that the jury's verdict was against the overwhelming weight of the evidence and asked the Supreme Court for a new trial. He believed he was entitled to such relief because there were conflicts between the State's evidence and his evidence, and the credibility of the State's main witness was called into question. The Supreme Court affirmed, finding Flowers's arguments were without merit. View "Flowers v. Mississippi" on Justia Law