Justia Constitutional Law Opinion Summaries

Roger Gillett was convicted of two counts of capital murder for which he was sentenced to death. Gillett petitioned for post-conviction relief, raising six issues for the Supreme Court's review: (1) the underlying capital-murder aggravator of robbery was improperly expanded; (2) conviction of capital murder under the “continuous-action doctrine” was unconstitutional; (3) Gillett’s trial counsel was ineffective in failing to investigate Gillett’s background and to present an adequate mitigation case; (4) Gillett’s trial counsel were ineffective in failing to object to prosecutorial misconduct during the sentencing portion of his trial; (5) Gillett’s due-process rights were violated when the Mississippi Supreme Court reweighed the aggravating and mitigating factors; and, (6) cumulative error. Upon review of the briefs submitted by Gillett and the state, the Supreme Court found issues one and two were without merit; however, under issue five, Gillett’s due-process rights were violated in sentencing. Therefore, the Court granted Gillett’s petition in part and denied in part, vacated his death sentences and remanded the case to the circuit court for a new sentencing hearing. View "Gillett v. Mississippi" on Justia Law

Timothy Pryer sought from the circuit court: “the Order givin[g] Carol Gates the Office of Judge de facto or pro tempore and the order givin[g] Carol Gates authority to appoint indigent counsel for December 2, 2004 [hearing] and the names of the 40 plus souls and their addresses according to the record.” The Itawamba County Circuit Court issued an order “denying Pryer records and construing a request for records as a petition for Post-Conviction Relief (PCR)." Pryer then filed a petition for writ of mandamus to the Supreme Court, requesting that it direct the circuit judge to enter an order on a “Motion to Show Cause.” The Supreme Court granted the petition for writ of mandamus, and the circuit court proceeded to enter an order that denied Pryer’s motion, explaining that the documents requested were “not contained with the Circuit Clerk’s file” and that “[t]his motion contains the exact same requests as the previously filed motions.” The court continued, “the Motion to Show Cause contains completely unfounded and slanderous allegations against several court officials.” The Court of Appeals affirmed the judgment of the Itawamba County Circuit Court, holding that “we have no reason to believe that any such documents do exist. It further appears that Pryer is merely on a ‘fishing expedition’ for grounds upon which to attack his conviction and sentence.” Finding no reversible error, the Supreme Court affirmed the appellate court's decision. View "Pryer v. Mississippi" on Justia Law

LeDarius Bonds was convicted by jury of murder and sentenced to life in prison. Bonds appealed his conviction, arguing that the trial court erred in admitting "Exhibit 39," a gruesome photograph that he contended was more prejudicial than probative, and that the trial court erred in allowing a jury instruction which informed the jury that it could infer malice from the use of a deadly weapon. Finding that Exhibit 39 was far more prejudicial than probative, the Supreme Court reversed the conviction and remanded for a new trial. View "Bonds v. Mississippi" on Justia Law

A jury found Daryl Conner guilty of burglary and felony fleeing a police officer, and the Circuit Court sentenced him as a habitual offender to two consecutive life sentences. Conner appealed to the Court of Appeals, which affirmed his convictions and sentences. On appeal to the Supreme Court, Conner argued the evidence was insufficient to support his conviction for felony fleeing, that the trial court erred by failing to instruct the jury on the elements of larceny, and that, because the pen packs establishing Conner’s habitual-offender status were not admitted at the sentencing hearing, the trial court erred by sentencing him as a habitual offender. The Supreme Court affirmed the appellate and trial courts, finding the evidence was sufficient to support Conner’s felony-fleeing conviction and that the jury was fully and fairly instructed. Furthermore, the pen packs establishing Conner’s status as a habitual offender were admitted at the sentencing hearing. View "Conner v. Mississippi" on Justia Law

A jury convicted Ryan Abeyta of the murder of his mother, for which he was sentenced to life in the custody of the Mississippi Department of Corrections. Abeyta appealed, arguing that he was entitled to a jury instruction on heat-of-passion manslaughter, that the evidence of deliberate design was insufficient to support the verdict, and that the trial court abused its discretion by admitting gruesome photographs of the victim. Upon review, the Supreme Court concluded Abeyta’s issues were without merit and affirmed the trial court. View "Abeyta v. Mississippi" on Justia Law

Sixteen-year-old Bernard Taylor fired multiple shots into a car containing five people, wounding three of them. He was charged with three counts of aggravated assault, with each count alleging a firearms enhancement. The trial court denied Taylor’s proposed jury instruction on the lesser-included offense of simple assault. Taylor was granted a self-defense instruction. The jury was not instructed on the firearms enhancement. Taylor was convicted of one count of aggravated assault. Taylor received a twenty-year sentence for aggravated assault and a five-year sentence for a firearms enhancement, to run consecutively. On appeal, Taylor argued that the district court erred by denying the assault instruction, and that the five-year sentence enhancement should be vacated either under “Apprendi v. New Jersey,” (530 U.S. 466), or, alternatively, under double jeopardy. Upon review, the Mississippi Court found that Taylor’s arguments were without merit and affirmed the circuit court. View "Taylor v. Mississippi" on Justia Law

Brad Hardy appealed his conviction of two counts of manslaughter by culpable negligence and one count of aggravated boating under the influence of alcohol resulting from a boating collision. He was sentenced to forty-four years, with twenty-six to serve. Finding no error, the Supreme Court affirmed. View "Hardy v. Mississippi" on Justia Law

Gregory Hopkins was convicted as a habitual offender of possession of cocaine with intent to distribute. On appeal he challenged the sufficiency and the weight of the evidence as well as the admission of evidence of his prior bad acts. Finding no error, the Supreme Court affirmed. View "Hopkins v. Mississippi" on Justia Law

A jury convicted Charles Ervin (a convicted felon) of armed robbery and as a felon in possession of a handgun following the armed robbery of the Healthy Body Store. Police were able to identify Ervin as a suspect after his brother, also a convicted felon, pointed the police in his brother’s direction. At trial, the trial court gave a flight instruction over Ervin's objection. The trial court sentenced him and included a gun enhancement in the sentencing. This appeal followed. Because the trial court improperly limited the defense’s cross-examination of a key State witness, the Supreme Court reversed Ervin’s convictions and remanded the case to the trial court for a new trial. View "Ervin v. Mississippi" on Justia Law

Eric Moffett was convicted of capital murder and sentenced to death by a jury. Moffett was convicted of a savage sexual assault on a five-year-old girl, resulting in her death. Moffett’s conviction and sentence were affirmed by the Supreme Court on direct appeal, and his motion for rehearing was subsequently denied. Moffett presented a motion, an amended motion, and a supplemental motion seeking post-conviction relief. Moffett's argument to the Supreme Court was focused primarily on ineffective-assistance-of-counsel claims, but finding to merit to any of them, the Supreme Court denied relief. View "Moffett v. Mississippi" on Justia Law