Justia Constitutional Law Opinion Summaries

Defendant Steve Antonio Anthony was convicted in circuit court for selling cocaine. He appealed his conviction, arguing that: (1) the circuit court erred by excluding evidence on cross-examination of the prior felony charges of the State's confidential informant; (2) the circuit court erred in denying two peremptory challenges raised by the defense; and (3) the jury's verdict was against the overwhelming weight of the evidence. The Court of Appeals affirmed the conviction. Defendant raised the same issues in his appeal to the Supreme Court which found that the trial court erred by limiting the cross-examination of the confidential informant. Accordingly the Court reversed Defendant's conviction and remanded the case for a new trial. View "Anthony v. Mississippi" on Justia Law

Roundstone Development, LLC, sought to develop an affordable-housing subdivision in the City of Natchez. The land which it sought to develop had two different zoning classifications: O-L (Open-Land) and R-1 (Single-Family Residential). The City’s Planning Commission denied Roundstone's site plan, finding that the O-L area must be rezoned R-1 before the development could be approved. The Mayor and Board of Alderman then denied Roundstone's rezoning request. The Circuit Court of Adams County and the Court of Appeals both affirmed the City’s decision. The Supreme Court granted certiorari to address: (1) whether the City erred in requiring that the O-L area be rezoned R-1 and (2) whether the City erred in failing to grant Roundstone's rezoning request. Upon review, the Court found that the City’s interpretation of its zoning ordinance to require rezoning from O-L to R-1 was not manifestly unreasonable and that it did not act arbitrarily or capriciously in denying the rezoning. Therefore, the Court affirmed the judgments of the circuit court and the Court of Appeals. View "Roundstone Development, LLC v. City of Natchez" on Justia Law

Robert Lee Jenkins was convicted for possession of a controlled substance. He was sentenced to life imprisonment under the habitual-offender statute. The Supreme Court granted Jenkins's petition for writ of certiorari to examine whether the trial court erred by allowing a laboratory supervisor to testify regarding the results of substance testing, where the supervisor reviewed and verified the results, but another analyst actually performed the tests. Finding no error, the Court affirmed. View "Jenkins v. Mississippi" on Justia Law

Frederick Denell Grim was convicted by jury for the sale of cocaine. The circuit court adjudicated Grim a habitual offender and sentenced him to life imprisonment without the possibility of parole. The Court of Appeals affirmed the trial court's judgment of conviction and sentence. The Supreme Court granted Grim's petition for writ of certiorari to examine whether the trial court erred by allowing a laboratory supervisor, who neither observed nor participated in the testing of the substance, to testify in place of the analyst who had performed the testing. Finding no error, the Court affirmed. View "Grim v. Mississippi" on Justia Law

In this interlocutory appeal, the issue before the Supreme Court was whether the Circuit Court of Simpson County erred in ordering Defendants to produce a recorded statement and a privilege log of all documents withheld on the basis of privilege and relevance. Upon review of the matter, the Court found that the circuit court abused its discretion in ordering Defendants to produce the recorded statement without any analysis of their claim of work-product privilege. Additionally, the Court found that the circuit court erred by granting Plaintiff’s motion to compel discovery without conducting an item-by-item analysis of each objection. Therefore, the Court vacated the circuit court’s order and remanded the case for further proceedings. View "Powell v. McLain" on Justia Law

Pro se prisoner Edgar Earl Patton appealed his convictions on false pretense and fraudulent use of identity. He argued: (1) the circuit court judge engaged in improper ex parte communications; (2) he was denied his Sixth-Amendment right to counsel at all critical phases; (3) the circuit court erred in denying his motion to recuse the trial judge; (4) the circuit court erred by allowing a substantive amendment to the indictment; (5) he was denied the right to compulsory service of process; (6) Patton’s Fourth-Amendment protection against unlawful search and seizure was violated; (7) the circuit court erred by violating Uniform Circuit and County Court Rule 1.11; (8) the circuit court judge’s inquiry into Patton’s educational background for purposes of determining his ability to represent himself was an improper discovery tool that benefitted the State and violated his Fifth-Amendment right against self-incrimination; (9) the circuit court erred by denying Patton’s motion for directed verdict; (10) jurisdiction was improper and venue was not established; (11) the jury was improperly instructed; and (12) the indictment was legally insufficient and defective. Finding no reversible error, the Supreme Court affirmed Patton’s convictions and sentences. View "Patton v. Mississippi" on Justia Law

Howard Goodin appealed a circuit court's denial of his application for post-conviction relief. The circuit court denied Goodin’s claims that he was mentally retarded and that he had received ineffective assistance of counsel on the issues of mental illness and competency. After review of the record and pertinent authorities, the Supreme Court found that the circuit court erred in determining that Goodin was not mentally retarded. The Court also found that Goodin failed to prove ineffective assistance of counsel regarding competency at the conviction stage. Because these issues were dispositive, the Court did not address Goodin’s claim of ineffective assistance of counsel on the issue of mental illness. The circuit court's judgment was affirmed in part and reversed in part. Goodin's death sentence was vacated and this case was remanded to the Circuit Court of Newton County for resentencing on the capital murder charge. View "Goodin v. Mississippi" on Justia Law

The issue on direct appeal to the Supreme Court in this case involved Quincy Clayton's conviction for the murder of his wife Alice. The Court found the trial court erred in depriving Clayton submission of an alternative theory of defense, when his requested jury instruction on heat-of-passion excusable homicide was refused. Accordingly, the Court reversed and remanded this case to the Jones County Circuit Court for a new trial. View "Clayton v. Mississippi" on Justia Law

A Harrison County grand jury indicted Mark Kee Brown for felony escape, and as a habitual offender under Mississippi Code Section 99-19-81. The State later moved the trial court to amend the grand jury’s indictment to charge Brown as a habitual offender under Section 99-19-83 – a statute that requires a life sentence for defendants with two previous felony convictions, one of which was a “crime of violence.” The trial judge held that a prior conviction for burglary satisfied the violent-crime requirement for habitual-offender status, even though the State had produced no evidence that the burglary involved violence. Brown appealed. Because burglary is not a crime against the person, and not, as the Court of Appeals held, a per se crime of violence, the Supreme Court reversed the lower courts and remanded this case for further proceedings. View " Brown v. Mississippi" on Justia Law

The Jackson County Court sitting as Youth Court exercised jurisdiction over two minors following allegations of abuse and neglect. The foster parents of the two minor children subsequently filed adoption proceedings in the Lincoln County Chancery Court. The Mississippi Department of Human Services ("MDHS") sought interlocutory appeal after unsuccessfully challenging the chancery court's jurisdiction to consider the adoption proceedings. Upon review, the Supreme Court found that the Chancery Court had jurisdiction over the adoption proceedings and affirmed the Chancery Court's judgment. View "Mississippi Dept. of Human Svcs. v. Watts" on Justia Law