Justia Constitutional Law Opinion Summaries

Mark Matthews was convicted of simple assault and disorderly conduct in Madison County Municipal Court. The decision was affirmed on appeal by the County Court of Madison County and the Madison County Circuit Court. The Court of Appeals found no error and also affirmed. While the Supreme Court also found no error in the Court of Appeals' decision, the Court took the opportunity of this case to clarify the proper burden of proof when the "Castle Doctrine" is asserted as a defense. View "Mathews v. City of Madison" on Justia Law

Jeffrey Yeatman pled guilty to one count of simple assault on a law-enforcement officer and two counts of third-offense driving under the influence. Each of the three counts had a separate cause number. The Circuit Court sentenced him: for simple assault on a law-enforcement officer (cause number 2006-0161-CR), five years imprisonment and a fine of $5,000 as a habitual offender; for third-offense DUI (cause number 2006-0327-CR), five years imprisonment and a fine of $5,000 as a habitual offender; and for third-offense DUI (cause number 2006-0328-CR), one year imprisonment, four years of post-release supervision, and a fine of $100. All sentences were to run consecutively. Yeatman sought post-conviction relief from his convictions for simple assault on a law-enforcement officer and third-offense DUI. The trial court denied post-conviction relief, and the Court of Appeals affirmed. The Supreme Court granted Yeatman's petition for a writ of certiorari. Because, by statute, the fine for simple assault on a law-enforcement officer was a maximum of $1,000, the Supreme Court vacated the $5,000 fine imposed on Yeatman for that crime, and remanded that case to the trial court for a determination of whether the criminal information in cause number 2006-0327-CR charged Yeatman as a habitual offender. The Supreme Court affirmed the trial court in all other respects. View "Yeatman v. Mississippi" on Justia Law

Alisha Vanwey pled guilty in 2007 to three counts of selling hydrocodone, and the trial court sentenced her as a habitual offender to eleven years on each count, to run concurrently, in the custody of the Mississippi Department of Corrections. Vanwey filed a petition for post-conviction relief (PCR) arguing, inter alia, that one of the two prior predicate felonies listed in her indictment alleging habitual-offender status did not meet the requirements of Section 99-19-81. The trial court denied the motion, and the Court of Appeals affirmed the trial court's decision based on the finding that Vanwey's motion was procedurally barred as a successive writ and time-barred. After its review, the Supreme Court found Vanwey waived whatever contention she might have had with her habitual-offender status when she failed to challenge the sufficiency or validity of her two prior felony convictions and sentences at her plea hearing and then voluntarily and intelligently entered her guilty plea to three counts of selling hydrocodone as a habitual offender. View "Vanwey v. Mississippi" on Justia Law

Plaintiffs Frank Schmidt Sr. and other former parishioners of the St. Paul Catholic Church in Pass Christian appealed the second dismissal with prejudice of their claims against the Catholic Diocese of Biloxi, Inc., Most Reverend Thomas J. Rodi, and Rev. Dennis Carver. In 2005, Hurricane Katrina ravaged the Mississippi Gulf Coast. The storm caused extensive damage to the St. Paul Catholic Church and its ancillary properties. The actual church building was also damaged, although the extent of the damage is disputed by the parties. Plaintiffs insisted that the church remains structurally sound, that many of its sacred articles were unharmed, and that repair costs should be less than $2.5 million. Church Defendants maintain that the church and its most sacred places were “destroyed in large part.” Bishop Rodi issued a decree merging the St. Paul and Our Lady of Lourdes Parishes to form a new parish called the Holy Family Parish. The decree stated that the Holy Family Parish would maintain two church edifices, St. Paul Church and Our Lady of Lourdes Church. A number of St. Paul’s former parishioners, including some of the Plaintiffs in this case, filed a canonical appeal through the Roman Catholic Church’s ecclesiastical tribunals. In 2007, the Vatican issued a decree which stated that Bishop Rodi had acted in accordance with the requirements and procedures set forth under canon law. While the canonical appeal was pending, 157 former parishioners filed suit asserting, in part, that Bishop Rodi held the St. Paul Church property in trust for the members, that any financial contributions designated for reconstruction of the church were held in trust for that particular purpose, that Church Defendants had violated said trusts, and that Father Carver had made misrepresentations in soliciting donations for the rebuilding efforts. The Mississippi Supreme Court affirmed in part, finding that Plaintiffs lacked standing to assert the St. Paul property was held in trust for their benefit. However, the Court reversed and remanded the chancellor’s dismissal of the diversion-of-designated funds claim, as well as the claim against Father Carver for intentional misrepresentation, finding subject-matter jurisdiction existed over these claims. On remand, the chancellor denied Plaintiffs’ motions for additional discovery and granted Church Defendants’ motion for summary judgment, dismissing Plaintiffs’ claims with prejudice. Plaintiffs argued on appeal that the chancellor erred in dismissing their claims for diversion of designated funds and intentional misrepresentation. Because none of the Plaintiffs established the requisite elements for a diversion of designated funds, the Supreme Court affirmed the grant of summary judgment on this issue. In addition, because no Plaintiffs could establish a claim for intentional misrepresentation, the Court affirmed the grant of summary judgment on this issue. Therefore, the Court affirmed the Chancery Court's judgment. View "Kinney v. Catholic Diocese of Biloxi, Inc." on Justia Law

Frank Gideon Whitaker IV and Cynthia Ann Grantham were involved in a car accident. The Circuit Court found Whitaker guilty of aggravated driving under the influence pursuant to Mississippi Code Section 63-11-30(5), sentenced him to twenty-five years and ordered Whitaker to pay Grantham $25,000. Whitaker argued two issue on appeal, in both, contending a blood sample taken from Whitaker following the collision while he remained unconscious should not have been admitted into evidence. The majority of the Supreme Court concluded that Whitaker failed to raise any issue of merit: his blood was not drawn pursuant to the Mississippi Implied Consent Act, and he failed to satisfy his burden of showing that the evidence was tampered with or substituted, defeating his chain-of-custody argument. Furthermore, the Court found Whitaker failed to present any evidence supporting his claim that the blood sample was not properly authenticated. View "Whitaker v. Mississippi" on Justia Law

Edward Myers appealed his conviction for the armed robbery of Gabriel Lewis. Upon review of the trial court record, the Mississippi Supreme Court found that the trial court abused its discretion in excluding the testimony of a defense witness where there was no evidence of a willful discovery violation. Accordingly, the Court reversed Myers’s conviction and remanded for a new trial. On remand, the Court directed the trial court to conduct a hearing to determine whether Myers’s right to a speedy trial was violated. View "Myers v. Mississippi" on Justia Law

Carey Witten was convicted in Sacramento County, California, of oral copulation and rape of a person “. . . unconscious of the nature of the act . . .” in violation of the California Penal Code. Witten was granted five years’ probation, and he received an order of dismissal after successful completion of his probation. Witten relocated to Mississippi and filed a petition for relief from the duty to register in Mississippi Code. At the hearing on the matter, Witten argued that his order of dismissal from California satisfied the requirements of Mississippi Code Section 45-33-47(4), such that Witten should have been relieved of the duty to register as a sex offender in Mississippi. The assistant district attorney agreed with Witten. The trial court also agreed and subsequently entered an order relieving Witten of the duty to register as a sex offender in Mississippi. R. Steven Coleman, on behalf of the Mississippi Department of Public Safety, Criminal Information Center, Sex Offenders Registry, filed a Mississippi Rule of Civil Procedure 60(b) motion to set aside and render as void the trial court’s order relieving Witten of the duty to register, based on Mississippi and California statutes that were not presented to the trial court at the hearing and that had bearing on whether or not Witten was required to register as a sex offender. The trial court ultimately granted the motion to set aside and render as void the earlier judgment. Witten appealed the Supreme Court, arguing the trial court erred as a matter of Mississippi law in its assessment of Mississippi Code Sections 45-33-23 and 45-33-47(4). The Court affirmed the trial court’s ruling, finding that Witten’s conviction had not been set aside or dismissed in accordance with Mississippi Code Section 45-33-47(4) and that Witten was required to continue registration as a sex offender in the State of Mississippi. View "Witten v. Mississippi" on Justia Law

Caleb Corrothers was convicted of two counts of capital murder, with the underlying felony of robbery, for the murders of Frank Clark and Taylor Clark. He was convicted on a third count of aggravated assault for the shooting of Tonya Clark. The jury sentenced Corrothers to death for the two counts of capital murder and to life imprisonment without the possibility of parole for the aggravated assault. The trial court denied Corrothers’s post-trial motions. He appealed. Finding no reversible error, the Supreme Court affirmed Corrothers’s convictions and sentences. View "Carothers v. Mississippi" on Justia Law

Because Rudy Quilon was homeless following his release from prison, defendant Harvill Richardson permitted Quilon to move into his home while he got back on his feet. Over the next five months, Quilon "became increasingly unwelcome" as he bragged about having been convicted for murder and armed robbery, his previous experiences as a gang member, and killing a “snitch” in prison. On numerous occasions, Richardson attempted to persuade Quilon to leave the home, but Quilon claimed that he could not leave because he had no transportation or place to go. The situation culminated when Quilon, who had begun watching pornography on Richardson’s computer, stated that he wanted to have sex with Richardson’s wife. Despite having been asked to leave, Quilon refused and walked out to a shed behind the home where Richardson kept axes and other tools that could be used as weapons. Richardson armed himself with a pistol. As Quilon returned from the shed, he approached Richardson in a threatening manner, with one arm concealed behind his back. Quilon kept coming toward him, so Richardson shot Quilon in the stomach. Richardson was prodecuted for murder. The trial judge ruled in limine that Richardson would not be allowed to support his self-defense claim with evidence of the victim’s prior bad acts, including a violent criminal history. Because Richardson's knowledge of this evidence would be highly probative of the reasonableness of his conduct and fear of the victim, the Supreme Court reversed and remanded the case for a new trial. View "Richardson v. Mississippi" on Justia Law

Defendant Joe Cotton was convicted of murder for the shooting death of Fannie Lee Burks. He appealed his conviction, challenging the sufficiency and the weight of the evidence. Finding no error, the Mississippi Supreme Court affirmed defendant's conviction and sentence. View "Cotton v. Mississippi" on Justia Law