Justia Constitutional Law Opinion Summaries

In 2010, sixteen death-sentenced inmates, including Steve Knox (the inmates), filed a complaint in the Chancery Court. The essence of their complaint was that due to defects in both the statutory structure and the performance of the Mississippi Office of Capital Post-Conviction Counsel (MOCPCC), they were deprived of their right to obtain meaningful state post-conviction and federal habeas corpus review of their convictions and death sentences. The inmates requested injunctive relief against the State due to alleged violations of their rights to competent, appointed, post-conviction counsel. The State moved to dismiss for lack of jurisdiction. After a hearing, the chancery court found that it lacked subject matter jurisdiction over the complaint because the inmates' "attack on the death sentences and post-conviction judicial reviews of [their] convictions" was cognizable under the Uniform Post-Conviction Collateral Relief Act (UPCCRA). The chancery court dismissed the complaint. Upon review, the Supreme Court affirmed, finding the chancery court lacked jurisdiction over the inmates claims because the claims were embraced by the UPCCRA.

The Mississippi Commission on Judicial Performance (Commission) filed a Formal Complaint charging Youth Court Judge Leigh Ann Darby with violating various Canons of the Mississippi Code of Judicial Conduct and with "willful misconduct in office" and "conduct prejudicial to the administration of justice which brings the judicial office into disrepute[.]" Judge Darby held a mother in contempt of court for disobeying her verbal orders pertaining to the house arrest of the mother's fifteen-year-old daughter. The mother brought her complaint against the judge when "she wrongly imposed sanctions against [her] for contempt of court without first affording her the due process rights required in a criminal contempt matter." The judge and the Commission jointly proposed a recommendation that the judge be publicly reprimanded and fined. Upon review, the Supreme Court affirmed the Commission's recommendation, and ordered the judge be publicly reprimanded, fined $500 and assessed costs.

Defendant Brian Holliman was convicted for killing his wife. He was sentenced to life in prison. Defendant appealed his conviction and sentence, arguing to the Supreme Court that the prosecutor in his case made an impermissible "golden-rule" argument to the jury and that the trial court failed to instruct the jury to disregard the argument. Upon review of the trial court record, the Supreme Court found that the prosecutor's argument was a blatant violation, and the trial court erred in overruling both objections from Defendant's counsel. The Court reversed the trial court's judgment and remanded the case for a new trial.

Defendant Alvin Johnson was convicted of possession of cocaine and sentenced to sixteen years' imprisonment with nine suspended and five years of post-release supervision and a fine. The Court of Appeals affirmed Defendant's conviction and sentence. Defendant petitioned the Supreme Court for a writ of certiorari concerning two issues: (1) whether the State presented sufficient evidence to sustain his conviction; and (2) whether the agents' search of a nearby vehicle violated Defendant's right to be free from unreasonable searches and seizures within the Fourth and Fourteenth Amendments to the United States Constitution and Sections 14 and 23 of the Mississippi Constitution. The Supreme Court granted Johnson’s certiorari petition, and found Defendant's first issue to be dispositive. The State failed to prove beyond a reasonable doubt that Johnson was in constructive possession of the cocaine found in the nearby vehicle. Therefore, the circuit court erred by denying Defendant's motion for judgment notwithstanding the verdict (JNOV). Finding that proximity alone was insufficient to show constructive possession, and that the State presented no additional incriminating circumstances, the Supreme Court reversed the Court of Appeals' judgment and that of the trial court and rendered judgment in Defendant's favor.

Defendant-Appellant David Shaffer was convicted of child exploitation for soliciting sex from a twenty-nine year old female who he thought was thirteen. He argued to the Court of Appeals that the could not be guilty of child exploitation because no actual child was involved in the sting. The Court of Appeals agreed, but reversed and remanded for Defendant to be sentenced for attempted child exploitation, a crime for which he was neither indicted nor tried. Upon review, the Supreme Court found that the actual attempt to exploit a child violated the child exploitation statute. The Court reversed the Court of Appeals and reinstated and affirmed Defendant's conviction and sentence.

John Fletcher, John McConnon, and Tom Leader (collectively, "Fletcher") appealed an order of the Chancery Court of Hancock County incorporating the City of Diamondhead, Mississippi. Fletcher argued that the chancery court lacked jurisdiction over the petition for incorporation because it did not include two-thirds of the signatures of the qualified electors residing in the proposed incorporation area, and notice was improper. Fletcher also argued that objectors to the incorporation were denied the right of cross-examination at the hearing, and that the second chancellor's failure to order a new trial was an abuse of discretion. The Supreme Court found that the petition for incorporation met the jurisdictional requirements, because notice was proper and the petitioners presented substantial evidence that the petition contained two-thirds of the signatures of the qualified electors residing in the proposed incorporation area. Furthermore, the Court found that the chancellor did not deny the objectors' right of cross-examination, and the second chancellor's decision not to order a new trial was within his discretion.

After a mistrial, Defendant Stephan Hickman was retried and found guilty of capital murder with the underlying felony of robbery. The circuit court sentenced Hickman to life without parole in the custody of the Mississippi Department of Corrections. Defendant appealed, arguing that the trial court erroneously restricted his right to cross-examine a witness in violation of his right to confrontation, and that the verdict was against the overwhelming weight of the evidence. Finding no error, the Supreme Court affirmed Defendant's conviction.

Defendant Gary Glidden was convicted of one count of possession of a controlled substance. The circuit court sentenced him to serve a term of four years in the custody of the Mississippi Department of Corrections. The court also sentenced Defendant to serve his imprisonment as an habitual offender. After entering an order denying Defendant's motion for a judgment notwithstanding the verdict, or in the alternative, for a new trial, Defendant perfected his appeal to the Supreme Court. Finding that no reversible error occurred at trial, the Supreme Court affirmed the judgment of the Court of Appeals, which affirmed the judgment of conviction and sentence of the circuit court.

Defendant Leo Wales was tried in absentia for two counts of armed robbery and two counts of aggravated assault. A jury found Defendant guilty on all counts, and the Circuit Court of Hinds County sentenced Defendant to twenty years, and forty years for each count of armed robbery and assault, each sentence to run concurrently in the Mississippi Department of Corrections. Defendant's consecutive and concurrent sentences required him to serve a total of eighty years. On appeal, Defendant argued that (1) the trial court erred in trying him in absentia; (2) the evidence was insufficient to support his conviction in Count I, aggravated assault or, alternatively, the verdict of guilty in Count I was against the overwhelming weight of the evidence; and (3) the trial court erred by denying his proffered jury instruction on the specific intent required for armed robbery. The Supreme Court affirmed Defendant's convictions and sentence, because it found substantial evidence supported the trial courtâs finding that he had waived his right to be present at trial, because the evidence was sufficient to support the verdict of guilty in Count I, and that verdict was not against the overwhelming weight of the evidence, and because the jury instructions, taken as a whole, fully and fairly informed the jury of each element of the crime of armed robbery.

Jules Corbin, Tammy Louis, and James Henry, Jr. were involved in an automobile wreck that left Louis dead and Henry severely injured. Corbin was indicted for capital murder, aggravated assault, and felony fleeing the scene of an accident. However, he was convicted by a jury on the lesser-included offense of murder, as well as aggravated assault and felony fleeing the scene. Corbin was sentenced to life imprisonment for murder, ten years for aggravated assault, and three years for felony fleeing. Corbin appealed, and claimed among other things, that his Sixth-Amendment right to confrontation was violated. Upon review of the trial court record, the Supreme Court agreed that Corbin's constitutional rights were violated, and that the error was not harmless as to the charges of murder and aggravated assault, but that it was harmless as to the charge of felony fleeing the scene of an accident. Thus, the Court reversed and remanded part, and affirmed part of the trial court's decision.