Justia Constitutional Law Opinion Summaries

Defendant Curtis Gause was indicted on capital murder charges in addition to burglary, and aggravated assault. A jury found him guilty of manslaughter and burglary, and not guilty of assault. The circuit court sentenced Defendant to twenty years for manslaughter and twenty-five years for burglary, with sentences to run consecutively in the state Department of Corrections. Defendant appealed, arguing multiple errors at trial. Principal among them, Defendant contended the trial court erred when it allowed the jury to consider a verdict on burglary. Upon careful consideration of the trial court's record and the applicable legal authority, the Supreme Court found that the trial court erred by granting the burglary jury instruction. The Court found that burglary was not a "lesser-included" offense to capital murder, and only Defendant could have asked for the "lesser-included" instruction. The Court affirmed Defendant's conviction on manslaughter, but reversed his conviction on burglary. The Court remanded the case for further proceedings.

A grand jury indicted Vanessa Decker under the state Vulnerable Adults Act of 1986 for using her elderly mother's money "without her consent." But at trial, the evidence established that Ms. Decker did obtain her mother's consent to use the money. The State requested a jury instruction that allowed the jury to find Ms. Decker guilty, even if her mother had given consent. The judge granted the State's request. Subsequently, Ms. Decker was convicted by the court and sentenced to four months' imprisonment. Additionally, Ms. Decker was sentenced to pay restitution, fines and court costs. Ms. Decker appealed her conviction. Upon review of the trial record, the Supreme Court found that the trial judge gave a jury instruction that materially changed the charge made by the grand jury in the indictment. Accordingly, the Court reversed the trial court's conviction and sentence. The Court remanded the case for further proceedings.

Defendant Gregory Redmond appealed his conviction of statutory rape. He was sentenced to life. On appeal to the Supreme Court, Defendant argued that the trial court made errors by admitting some and excluding other testimony that was ultimately prejudicial to his case. Upon consideration of the record and the applicable legal authority, the Supreme Court found no error by the trial court. The Court affirmed Defendant's conviction and sentence.

Defendant Dennis Taylor appealed his conviction for conspiracy and robbery. He was sentenced to fifteen years. On appeal to the Supreme Court, Defendant argued that the verdicts against him at trial were against the weight and sufficiency of the evidence. Upon consideration of the arguments and the applicable legal authority, the Supreme Court found that the evidence was sufficient to support the jury's verdicts, and that the verdicts were not against the overwhelming weight of the evidence. The Court affirmed Defendant's conviction and sentence.

A grand jury indicted Defendant Harold Hargett for selling marijuana and hydrocodone. A jury found Defendant guilty, and he was sentenced as a habitual offender to six years for the marijuana charge, and sixty years for the hydrocodone charge. The appellate court affirmed Defendant's sentence. Defendant appealed to the Supreme Court by arguing that the trial court erred by admitting testimony that referenced certain "prior bad acts" that should have been excluded. Before trial began, defense counsel argued in a motion to exclude evidence that Defendant's prior convictions would be too prejudicial. The trial court granted the motion. Despite the ruling, the State continually elicited inadmissible testimony that referenced the prior convictions. The Supreme Court reversed the decisions of the trial and appellate courts and remanded the case for a new trial. The Court found that the testimony that referenced Defendant's prior bad acts should have been excluded.

Appellee Charles Buckner filed a personal-injury action against the Copiah County School District and Kenneth Funches. Appellee failed to serve process on either Defendant within the 120-day period provided by the state rules of civil procedure. After running the statute of limitations, Appellee moved for an extension of time to effect service of process. The trial court granted the motion, and allowed Appellee an additional 120 days to effect service. Appellee failed to serve Defendants under the second 120-day period. Defendants moved to set aside the extension granted to Appellee and moved to dismiss the case, but the trial court denied the motions. Defendants appealed to the Supreme Court, arguing that the trial court abused its discretion in granting Appellee two 120-day periods to effect service of process. The Supreme Court found that the statute of limitations had run before Appellee first asked for an extension of time. It ruled, therefore, that the trial court did abuse its discretion by granting the extension. The Court reversed the trial court, effectively dismissing Appelleeâs case against Defendants.

In September, 2007, a grand jury returned a two-count indictment against Defendant Albert Joiner. One count charged Defendant with âfelony flight,â and the second count charged Defendant with being a felon in possession of a deadly weapon. The indictment did not charge Defendant as being a âhabitual offender.â In a separate case, Defendant had a pending indictment for armed robbery as a habitual offender. Defendant and the State reached a plea agreement: the State would dismiss the possession charge and reduce the armed-robbery charge if Defendant would plead guilty to felony flight and robbery as a âlesser habitual offender.â Defendant accepted the deal, pled guilty, and was sentenced to a total of nineteen years as a habitual offender. Defendant moved for post-conviction relief, arguing that the trial court erred by charging him as a habitual offender when the grand juryâs indictment made no mention of it. The trial judge summarily denied his petition, and Defendant appealed. The Supreme Court found that because of Defendantâs âknowing an voluntary guilty plea,â Defendant waived his right to contest any deficiency in the indictment. The Court affirmed the lower courtsâ decisions.