Justia Constitutional Law Opinion Summaries

A 2011 amendment to Section 71-3-51 provides that, "from and after July 1, 2011," decisions of the Mississippi Workers' Compensation Commission may be appealed directly to the Supreme Court, rather than to the circuit court, as required under the previous version of the statute. On July 1, 2011, the Commission denied Petitioner Joseph Dewayne Johnson’s claim for benefits, so he appealed to the Supreme Court. The ordered the parties to brief two issues: whether Section 71-3-51, as amended was constitutional; and whether the Court had appellate jurisdiction over direct appeals from the Commission. Upon review, the Court concluded that Section 71-3-51 was constitutional, and that the Court had appellate jurisdiction over direct appeals from the Commission.

In 1992, Defendant Jeffrey Davis was convicted of murder and sentenced to death. After the Supreme Court affirmed his conviction and sentence on direct appeal, he filed a petition for post-conviction relief, claiming, among other things, that he was denied effective assistance of counsel at the sentencing phase of his trial. Based on the evidence produced by Defendant's new counsel (evidence that was available to but never discovered or produced by his trial counsel), the Court reversed the trial court's denial of post-conviction relief and remanded the case for a new sentencing trial.

Property owners (collectively, "the Rhalys") sued the City of Jackson for flooding to their properties allegedly caused by the City's failure to maintain a ditch. The Circuit Court of Hinds County struck the City's answer due to "gross indifference to its discovery obligations," based upon its failure to produce the "Streets, Bridges, and Drainage Division of the Public Works Department Operations and Maintenance Policy Manual." The court entered a default judgment in favor of the Rhalys. The Court of Appeals affirmed. The City appealed. Upon review, the Supreme Court concluded that the City indeed exhibited "gross indifference to its discovery obligations" and affirmed both the circuit court and the Court of Appeals.

The Supreme Court granted certiorari in this case to address whether in a driving-under-the-influence trial, the admission of intoxilyzer calibration records, in lieu of the live testimony of the person who calibrated the Clause contained in the Sixth Amendment to the United States Constitution. Finding no constitutional violation, the Court affirmed the judgments of the Court of Appeals and the Madison County Circuit Court: "[the are nontestimonial in nature. Therefore, [Defendant's] Confrontation-Clause rights were not violated."

The issue before the Supreme Court concerned a custody dispute on interlocutory appeal. The Lauderdale County Youth Court denied Theresa and Ralph Anderson's Motion to Transfer Jurisdiction to the Chancery Court of Neshoba County in the matter involving neglected and abused minors. Aggrieved, the Andersons appealed, arguing that the youth court erred in retaining jurisdiction over the matter because chancery courts have jurisdiction over custody matters, and because the youth court previously terminated its jurisdiction over the minors involved. Upon review, the Supreme Court found no error and affirmed the order of the youth court denying the Motion to Transfer Jurisdiction.

In 2006, Defendant Ladennis Graham pled guilty to simple possession of approximately twelve grams of cocaine. The circuit court sentenced Defendant to serve sixteen years in the Mississippi Department of Corrections (MDOC) with fifteen years to be suspended upon the successful completion of twelve months of house arrest, four years of supervised post-release supervision and completion of a community service program. While Defendant was on house arrest, MDOC determined he violated the conditions of his suspended sentence when he was arrested at his brother's house during the execution of a search warrant, which turned up a number of guns and narcotics. Defendant was required to serve the remainder of his sixteen-year sentence as an inmate. Defendant then filed a motion for post-conviction relief (PCR) which was dismissed for lack of subject matter jurisdiction. On appeal, the Court of Appeals found that Defendant's sentence was illegally vague and indeterminate, and remanded the case for revocation of Defendant's sentence if the circuit court or State chose to initiate such a proceeding. Upon review, the Supreme Court concluded the Court of Appeals was correct in reversing the circuit court’s ruling that it did not have proper jurisdiction to hear Defendant's motion for post-conviction collateral relief. However, it was improper for the Court of Appeals to rule on the merits of Defendant's motion without the circuit court doing so first, as the circuit-court had exclusive, original jurisdiction. The judgment of the Court of Appeals was vacated; the circuit court judgment was reversed, and the case was remanded to the circuit court for further proceedings.

A jury in DeSoto County found Defendant Jeremy Rogers guilty of statutory rape, sexual battery, and fondling of his twelve-year-old stepdaughter, Mary. Defendant appealed his conviction, arguing that he was denied a fair trial by introduction of extensive prior-bad-acts evidence, and that he received ineffective assistance of counsel. Finding no merit to the issues Defendant raised on appeal after a review of the trial court record, the Supreme Court affirmed Defendant's conviction.

While attending a group-therapy session at St. Dominic’s Hospital (SDH) in 2005, Plaintiff Elizabeth Martin slipped and fell on a floor while it was being waxed. She alleged she received injury to both knees and sued SDH for negligence regarding her injuries allegedly caused by the fall. At the conclusion of the trial, SDH moved for a directed verdict, claiming that Plaintiff had not provided sufficient evidence to establish the proximate cause of her injury. The circuit court granted SDH's motion for a directed verdict, and Plaintiff timely filed an appeal. The Court of Appeals reversed the decision of the circuit court and remanded the case for a new trial, finding that Plaintiff had provided enough evidence to create a question of fact for the jury to make a determination based on the totality of the evidence. Upon review, the Supreme Court disagreed and found that the circuit court correctly granted SDH's motion for a directed verdict.

Defendant Tadise Seales was convicted of grand larceny following a jury trial in the Neshoba County Circuit Court. Defendant appealed his conviction, asserting that the trial court erred: (1) by not suppressing his confession; and, (2) in denying his motion for a directed verdict. "Finding no merit to either averment," The Supreme Court affirmed the trial court.

In 1994, Defendant Joseph Patrick Brown (a.k.a. Peanut Brown) was convicted of capital murder for shooting a convenience-store clerk to death on August 8, 1992, during the commission of an armed robbery. Defendant was sentenced to death by lethal injection. His conviction and sentence were affirmed by the Supreme Court. On March 17, 1998, Defendant filed an application for post-conviction relief, which the Supreme Court granted in part, for the sole purpose of determining whether Defendant's trial counsel was ineffective for failing to seek an independent psychological evaluation of Defendant for use as mitigation evidence. A special judge appointed to hear the matter denied Defendant's petition for post-conviction relief, and Defendant appealed. Upon review, the Supreme Court concluded the trial court did not abuse its discretion in denying Defendant's motion for discovery, as he failed to show "good cause" for his request. Furthermore, Defendant did not demonstrate that his trial counsel was ineffective in not introducing, as mitigation, a report of Defendant's psychological evaluation or in further investigating Defendant's psychological state. The Court therefore affirmed the trial court's decision to deny Defendant's petition for post-conviction relief.