Justia Constitutional Law Opinion Summaries

Articles Posted in Supreme Court of Mississippi
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Courtney Rainey was indicted on two counts: (I) voter fraud; and (II) witness intimidation. The jury found Rainey guilty of Count II but could not decide on Count I, and the circuit court declared a mistrial as to Count I. On the conviction for Count II, Rainey was sentenced to serve fifteen years with three years suspended and five years’ probation, together with court costs and fees. The circuit court denied Rainey’s post-trial motions. A divided Court of Appeals reversed and rendered Rainey’s conviction and sentence, finding insufficient evidence to support conviction under Count II. The State filed a petition for writ of certiorari arguing that the Court of Appeals erred in finding insufficient evidence relating to Rainey’s conviction for witness intimidation, and that Rainey’s sentence did not amount to cruel and unusual punishment under the Eighth Amendment. After review, the Mississippi Supreme Court reversed the Court of Appeals and reinstated and affirmed the circuit court's judgment. View "Rainey v. Mississippi" on Justia Law

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Bobby Batiste was convicted of capital murder for which he was sentenced to death. The Mississippi Supreme Court later granted Batiste the right to file a petition for post-conviction relief (PCR) ("Batiste II") because the Court determined he was entitled to a hearing regarding alleged communications between bailiffs and/or others and members of the jury. During the hearings on Batiste’s PCR petition, a motion requesting the recusal of the trial judge was made, arguing that the judge's own memory of an alleged conversation with a juror could be relied on in witness-credibility determinations while evaluating the merits underlying the PCR petition. This motion was denied and, ultimately, the PCR petition was denied. Batiste appealed both the denial of the motion to recuse as well as the denial of the PCR petition on the merits. In September 2020, having found that evidentiary questions remained relating to the recusal issue, the Supreme Court declined to address the merits of the PCR petition and remanded the case (Batiste III). On November 20, 2020, the circuit court held a hearing pursuant to the Supreme Court's directions for remand in Batiste III “for the limited purpose of allowing the trial judge to hear such evidence as is necessary to allow him to clear up any ambiguity and to determine if the alleged conversation did, in fact, take place ‘during trial,’ and, if it did, whether the conversation is alleged to have occurred on or off the record.” After that hearing, the circuit court found that the alleged discussion between the court and the witness took place after the guilt and the Supreme Court affirmed the circuit court’s denial of Batiste’s motion to recuse and his PCR petition. View "Batiste v. Mississippi" on Justia Law

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Janarious Jones was indicted by grand jury for for first-degree murder. A jury would ultimately convict him of manslaughter, for which he was sentenced to prison for twenty years, with five years suspended. After denial of his post-trial motions, Jones appealed, arguing: (1) the circuit court erred by not requiring the jury to specify which theory of manslaughter the jury used to convict Jones; (2) the State presented insufficient evidence to support a heat-of-passion manslaughter conviction; and (3) the circuit court committed reversible error when it dispersed the jury for lunch. Finding no error, the Mississippi Supreme Court affirmed Jones’s conviction and sentence. View "Jones v. Mississippi" on Justia Law

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While he was incarcerated, Lavar Williams’s jailers recorded numerous telephone conversations in which Williams appeared to be directing a drug trafficking ring. A search of Williams’s home revealed large amounts of marijuana and cocaine, as well as $93,259 in cash. Williams was subsequently charged and convicted of two counts of conspiracy and two counts of possession with intent to distribute. On appeal, Williams contended that he could not be in possession, constructive or otherwise, of drugs found in his home when he had been had been incarcerated for two months and others had access to the home. The Court of Appeals affirmed Williams’s conviction on a constructive possession theory. The Mississippi Supreme Court affirmed too, though the Court took this opportunity to clarify that Williams’s conviction should have been affirmed based on accomplice liability rather than constructive possession. View "Williams v. Mississippi" on Justia Law

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Jabrien Williams was twenty-two years old when he convinced fourteen-year-old JR to unlock the window of an unoccupied bedroom of her family’s ground-floor apartment. Once inside, Williams had sex with the JR. Days later, Williams texted JR, attempting to have sex with her again. Soon after, JR’s stepfather discovered the messages on the family’s iPod. JR told her stepfather that Williams sent the messages to her. She then informed her mother she had sex with Williams in their apartment. Williams was indicted on one count of sexual battery. Before trial, Williams’s counsel disclosed that one of Williams’s defense theories would be that someone else—namely, Williams’s younger brother, who went to school with JR—sent the text messages from Williams’s phone. But at trial, Williams employed a different defense, steadfastly denying that the phone number used to send JR the messages was his. His younger brother also testified the number was not Williams’s. The State ran the phone number through the Madison County Detention Center logs. After the State rested, it learned this exact phone number was listed by Williams as his contact number when he received an ankle monitor for an unrelated crime. Realizing Williams had been wearing the GPS monitor during the relevant time frame, the State inquired further and learned GPS coordinates placed Williams at JR’s apartment the night she reported he had sex with her. Over Williams’s objection, the judge permitted the State to introduce this evidence during its rebuttal. On appeal of his conviction, Williams challenged several evidentiary rulings, significantly the admission of the State's rebuttal evidence. The Mississippi Supreme Court found no abuse of discretion in the trial court's ruling, and affirmed. View "Williams v. Mississippi" on Justia Law

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The Mississippi Court of Appeals vacated Norris Alexander’s life-without-parole sentence as a habitual offender under Mississippi Code Section 99-19-81 (Rev. 2020). The Court of Appeals held that the Circuit Court erred by denying Alexander’s motions for funds to hire a mitigation investigator and an adolescent-development psychologist for his Miller v. Alabama hearing. The State petitioned the Mississippi Supreme Court for certiorari, which was granted. Finding that the trial court did not abuse its discretion by denying the motions for expert funding, the Supreme Court reversed the Court of Appeals’ decision, and reinstated and affirmed the trial court’s sentencing order. View "Alexander v. Mississippi" on Justia Law

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Kobe Augustine was convicted of second-degree murder for the killing of Nigel Poole. A divided Court of Appeals reversed and remanded Augustine’s conviction, opining that the circuit court erred by admitting hearsay testimony and that the error was not harmless. The Mississippi Supreme Court reversed, finding that consistent with Mississippi law, the circuit court did not err by allowing an officer to testify to the content of a witness’s prior statement for the purpose of impeachment. But even assuming that doing so was erroneous, the evidence against Augustine overwhelmingly supported his conviction. View "Augustine v. Mississippi" on Justia Law

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Seth Copes was convicted on two counts of sexual battery of two minors. He was sentenced to twenty years on each count, to be served consecutively. Copes appealed, and the Court of Appeals affirmed his conviction and sentence. The Mississippi Supreme Court granted certiorari for the purpose of addressing Copes’s argument that he was denied his counsel of choice. Finding no reversible error, the Supreme Court affirmed Copes' convictions. View "Copes v. Mississippi" on Justia Law

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A D’Iberville police officer arrested Damian Brown after spotting a firearm during a traffic stop. Brown appealed his resulting conviction for three counts of possession of a controlled substance and one count of unlawful possession of a firearm by a convicted felon. The trial court sentenced Brown to a total of twenty-four years to be served day for day without the benefit of early release or probation under Mississippi Code Section 99-19-81 (Rev. 2020), the habitual offender statute. Brown’s defense counsel filed a motion for JNOV or, alternatively, a new trial. The court denied the motions. To the Mississippi Supreme Court, Brown contended the trial court erred in denying his motions. The Supreme Court concluded the jury instructions given fairly and accurately announced the law of the case concerning constructive possession. The Supreme Court further found the trial court did not abuse its discretion by denying Brown’s proposed jury instruction D-11 as it had already been fairly covered elsewhere in the instructions by the State’s jury instruction S-5, a more complete and accurate statement of the law. Furthermore, the Court concluded Brown was not entitled to a circumstantial evidence jury instruction based on Nevels v. Mississippi. Therefore, the Supreme Court affirmed the trial court. View "Brown v. Mississippi" on Justia Law

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Sedric Sutton sought compensation under Mississippi Code Sections 11-44-1 to -15 (Rev. 2019), Compensation to Victims of Wrongful Conviction and Imprisonment, after his conviction of possession of a controlled substance with intent to distribute was vacated by the Mississippi Supreme Court. He argued his conviction was reversed on grounds not inconsistent with innocence and that the crime he committed was not a felony. Because Sutton failed to demonstrate a genuine issue of material fact, the Mississippi Supreme Court affirmed the trial court's dismissal of his claims. View "Sutton v. Mississippi" on Justia Law