Justia Constitutional Law Opinion Summaries

Casey Woods was indicted on one count of first degree murder, stemming from the shooting of his girlfriend’s estranged husband. Woods also was indicted on one count of possession of a firearm by a convicted felon. The counts were severed and the case proceeded to trial solely on the murder charge. A jury found Woods guilty of second degree murder, for which Woods was sentenced as a habitual offender under Mississippi Code Section 99-19-83 to life in prison without the possibility of parole. Woods’s trial counsel did not file any post-trial motions. Woods appealed, arguing: (1) the evidence presented at trial was insufficient to overcome the presumption afforded by the Castle Doctrine that he acted reasonably when he killed Pierre Tenner; and (2) he received constitutionally ineffective assistance of counsel. Woods waived his insufficient evidence argument; however, the Mississippi Supreme Court reversed and remanded for a new trial based on ineffective assistance of counsel with regard to Woods’s trial counsel’s failure to file a post trial motion for a new trial challenging the weight of the evidence. View "Woods v. Mississippi" on Justia Law

Joseph Patton was convicted by jury of murdering his uncle with an ax to the throat. Patton appealed, claiming his trial was rendered fundamentally unfair by the trial court’s refusal to strike for cause two prospective jurors from the jury venire who said during voir dire examination they knew the decedent’s son. Finding no merit in Patton’s claim, the Mississippi Supreme Court affirmed Patton’s conviction. View "Patton v. Mississippi" on Justia Law

Laqunn Gary carjacked Vizavian Trent Darby at gunpoint. When Darby refused to get out of the car, Gary shot Darby in the head, killing him. At Gary’s trial, the jury watched a video of Gary confessing to killing Darby. The jury found Gary guilty of capital murder. He was sentenced to life in prison without parole. Prior to trial, Gary moved to suppress his confession, claiming he had not voluntarily waived his Miranda rights. The trial court ruled the confession was voluntary, but it reached this conclusion without holding a full suppression hearing in which the State carried the burden to prove voluntariness. Because this violated Gary’s due-process rights, the Mississippi Supreme Court remanded this case to the trial court to conduct a suppression hearing. On remand, the State presented one of the detectives who was present when Gary confessed. She testified Gary had not been coerced or promised any reward. Instead, Gary signed the Miranda waiver and answered the detectives’ questions voluntarily. Based on her testimony, the signed Miranda statement, and Gary’s demeanor during the video confession, the trial judge determined Gary’s confession was voluntary. After re-review of the suppression proceedings, the Supreme Court determined Gary’s confession was voluntary, and affirmed the trial court’s denial of the motion to suppress. The Court also found no merit to Gary’s claims that the evidence was insufficient, the verdict was against the overwhelming weight of the evidence, or reversal is warranted based on cumulative error. Thus the Court affirmed Gary’s capital murder conviction and sentence of life without parole. View "Gary v. Mississippi" on Justia Law

Eddrick Cyrus was convicted by jury on sale of less than two grams of a controlled substance. Cyrus appeals, arguing the verdict was against the overwhelming weight of the evidence and that he was entitled to a new trial. The Mississippi Supreme Court disagreed with Cyrus’ estimation of the evidence, and affirmed his conviction. View "Cyrus v. Mississippi" on Justia Law

The sole issue presented for the Mississippi Supreme Court’s review was the interpretation of Mississippi Code Section 11-44-7, which provided the method for determining attorney’s fees in a wrongful conviction and imprisonment case. The trial court held that the statute set out an escalation of fees tied to each stage of the case, capping the fee award at 25%. The Supreme Court agreed. View "Hall v. Mississippi" on Justia Law

John Cole was convicted by jury for possession of less than thirty grams of marijuana with the intent to distribute, and possession of a firearm by a convicted felon. He was sentenced as a habitual offender. As a result, Cole was sentenced to serve three years for the marijuana-related charge, and ten years for the possession of the firearm; the sentences were ordered to run consecutively. Cole filed post-trial motions, all of which were denied. On appeal, Cole challenged the sufficiency of the evidence presented against him. Finding no error, the Mississippi Sipreme Court affirmed his conviction. View "Cole v. Mississippi" on Justia Law

The circuit court dismissed as untimely Larry Christmas’s county court misdemeanor conviction on traffic charges (no proof of liability insurance). Christmas appealed the circuit court’s dismissal to the Mississippi Supreme Court. Because the record showed Christmas’s notice of appeal was filed too late and that Christmas failed to request an extension, the Supreme Court affirmed the dismissal. View "Christmas v. Mississippi" on Justia Law

Notwithstanding Garrett Ray’s appointed appellate counsel filing a “Lindsey” brief, certifying she had thoroughly examined the record and found no arguable issues supporting Ray’s appeal, he filed a pro se brief, arguing crack cocaine found in a cigarette pack he tried to discard when approached by officers was unlawfully obtained. He also insisted the State violated his constitutional right to confront an informant who provided information to narcotics officers, leading to his drug arrest. The Mississippi Supreme Court disagreed with both of Ray’s assertions: (1) Ray abandoned the cocaine by throwing it out of his vehicle’s window, thus, the drugs were not seized in violation of the Fourth Amendment; and (2) the informant did not testify and was not an eyewitness to or a participant in Ray’s drug possession, nor were the informant’s statements used against Ray, so the State was not obligated to disclose his or her identity, and there was no Sixth Amendment Confrontation Clause violation. Accordingly, the Court affirmed Ray’s conviction. View "Ray v. Mississippi" on Justia Law

In 2015, a grand jury indicted Tony Swinney for robbery with an enhancement for a crime committed against a victim of sixty-five years of age or older, and conspiracy to commit robbery. Earlier that year, Audrey Swinney drove her brother Tony and their cousin LaMarvin Swinney to rob “Bullets,” a convenience store in Flora, Mississipppi. Tony and LaMarvin entered the store and robbed Pyare Lal, the seventy-three-year-old proprietor of the store. A jury ultimately found Tony guilty on both counts of the indictment, and Tony was sentenced as a habitual offender under Mississippi Code section 99-19-83 (Rev. 2015) to life without the possibility of parole or early release for each count, with the sentences to run concurrently. The Mississippi Supreme Court found only that the evidence presented at the sentencing hearing would have met only the requirements of Section 99-19-81, vacated Tony’s sentences and remanded for resentencing. The Court found no other reversible error and affirmed in all other respects. View "Swinney v. Mississippi" on Justia Law

In 2011, Robert Terrell, through a middleman Archie Nicholson, recruited Ricardo Hawthorne to record forged property deeds purporting to convey John McLendon’s property to Hawthorne. Terrell and his coconspirators then used the forged deeds to fraudulently induce a timber company to buy the timber rights for $20,300 and, unbeknownst to McLendon, harvest his timber. A jury found Terrell guilty of timber theft, conspiracy to commit timber theft, false pretenses, and conspiracy to commit false pretenses. Because the evidence was sufficient to convict Terrell of both timber theft and false pretenses, the Mississippi Supreme Court affirmed those convictions and sentences. However, the Court agreed with Terrell that the evidence supported only one conspiracy between Terrell, Nicholson, and Hawthorne, not two. The Court therefore vacated his two conspiracy sentences and remanded those conspiracy convictions to the trial court with instructions to dismiss, at the State’s election, one of the conspiracy counts and resentence Terrell on the remaining conspiracy count. View "Terrell v. Mississippi" on Justia Law