Justia Constitutional Law Opinion Summaries

Edward Harvey was indicted for aggravated domestic violence and kidnapping. Following a jury trial, Harvey was convicted of aggravated domestic violence and acquitted of kidnapping. He was sentenced to twenty years in the custody of the Mississippi Department of Corrections. Harvey appealed his conviction, claiming that the trial court erred by: (1) prohibiting him from presenting relevant defense evidence; and by (2) allowing an improper jury instruction regarding prior-bad- act evidence. After review of the trial court record, the Mississippi Supreme Court found no merit to either issue and affirmed Harvey’s aggravated domestic violence conviction. View "Harvey v. Mississippi" on Justia Law

Ja’nekia Barton sought to disqualify Jennifer Adams-Williams as a candidate for county prosecutor in Bolivar County, Mississippi, for failing to meet the two-year residency requirement set forth by Mississippi Code Section 23-15-300 (Supp. 2022). The Bolivar County Circuit Court denied Barton’s petition, finding that Adams-Williams was clearly a resident of Bolivar County and had been for the required two-year residency period. Finding that the trial court applied the proper legal standard in its analysis and did not manifestly err in its factual findings, the Mississippi Supreme Court affirmed the judgment of the trial court. View "Barton v. Adams-Williams" on Justia Law

In January 2023, Joel Garner received a letter from the Perry County, Mississippi Election Commission, co-signed by the lone member of the Perry County Republican Executive Committee. The letter notified him that he did not meet the two-year residency requirement to run in the upcoming Republican primary for Perry County Supervisor, District 2. Garner petitioned for judicial review with the Perry County Circuit Court. The Mississippi Supreme Court appointed a special trial judge, who tried the qualification question de novo. After two days of evidentiary hearings, the circuit judge made thorough findings of fact and conclusions of law. The judge ordered that Garner’s name be placed on the primary election ballot. Garner’s opponent, District 2 Supervisor Kevin Shows, and the Perry County Republican Executive Committee (collectively, the Executive Committee) appealed that decision. Because substantial evidence supported the trial judge’s conclusion that Garner changed his residency in January 2021—more than two years before the District 2 Supervisor election—the Supreme Court affirmed the judgment directing that Garner’s name be placed on the ballot for the Republican primary to be held August 8, 2023. View "Shows, et al. v. Garner" on Justia Law

Alberto Garcia confessed to savagely raping a five-year-old girl and leaving her lifeless body, hanged by the neck, in a filthy trailer. He pled guilty to capital murder. And he waived his right to appeal his conviction. He also waived his right to jury sentencing. The trial judge sentenced him to death. Garcia appealed his sentence, and the Mississippi Supreme Court affirmed. Garcia filed two separate petitions for post-conviction relief (PCR): one with the trial court seeking to set aside his guilty plea; the other with the Supreme Court seeking to set aside his death sentence. The trial court denied Garcia's petition aimed at his guilty plea. The appeal before the Supreme Court here was the trial court's denial of his guilty-plea PCR. In his petition, Garcia contended his mental-health issues—in particular his new- claimed suffering from autism—rendered him incompetent and unable to plead guilty voluntarily. He also suggested his trial counsel was ineffective for not ensuring his psychological expert was sufficiently independent and for encouraging him to plead guilty. Following a hearing, the trial court issued a lengthy order explaining why Garcia had failed to sufficiently show he was entitled to post-conviction relief. Finding no reversible error in that judgment, the Supreme Court affirmed the denial of relief. View "Garcia v. Mississippi" on Justia Law

Martezzarien Welch was convicted by jury of statutory rape. Welch was identified by the victim, and his DNA matched semen found on the victim. On appeal, Welch argued he received ineffective assistance of counsel because his attorney failed to determine whether Welch’s father’s or great uncle’s DNA may have matched the semen found on the victim. He pointed out that both men were present at the home when the rape occurred. And he argued that because they were all related and shared DNA markers, it was possible that their DNA samples, had they been collected and tested, also would have matched the semen. The Mississippi Supreme Court determined that the record affirmatively showed counsel’s decision not to collect and test Welch’s father’s and great uncle’s DNA was reasonable trial strategy and was not deficient performance. Additionally, Welch was not prejudiced by his counsel’s decision. Therefore, the Court denied his ineffective-assistance-of-counsel claim with prejudice, and the Court affirmed his conviction and sentence. View "Welch v. Mississippi" on Justia Law

Brandon Spiers was arrested on charges of burglary of a dwelling and attempted sexual battery. He was convicted on both charges. Spiers was sentenced to serve twenty-five years under the supervision of the Mississippi Department of Corrections (MDOC) for the burglary-of-a-dwelling conviction, and he was sentenced to thirty years under the supervision of MDOC for the attempted sexual battery conviction. The sentence for attempted sexual battery was ordered to run consecutively with the burglary-of-a-dwelling sentence. Spiers appealed arguing: (1) the trial court erred by granting a jury instruction requiring Spiers to prove the affirmative defense of consent by clear and convincing evidence; and (2) the State engaged in prosecutorial misconduct during its closing argument. Upon review of the record, the Mississippi Supreme Court affirmed Spiers’s convictions. View "Spiers v. Mississippi" on Justia Law

Jerry Beale was convicted of two counts of attempted murder and was sentenced to serve thirty-five years in the custody of the Mississippi Department of Corrections. The Court of Appeals found no reversible error. The Mississippi Supreme Court granted certiorari because one of the issues raised by Beale had never been addressed by the Court: that his indictment was defective because it lacked the essential element of an overt act. Beale further argued that the jury instructions constructively amended the indictment. The Supreme Court found that Beale’s indictment correctly stated the necessary elements of attempted murder. Furthermore, the Court found that jury instructions 8 and 9 did not constructively amend the indictment. View "Beale v. Mississippi" on Justia Law

Justin Anderson was convicted by jury of first degree murder for the killing of Michael McLendon. He was sentenced to life in prison. On appeal, Anderson challenged his conviction and sentence, arguing: (1) the trial court erred by denying his heat of passion jury instruction; (2) the trial court plainly erred by allowing his confession to be presented to the jury; and (3) that the verdict was against the overwhelming weight of the evidence. Finding no error, the Mississippi Supreme Court affirmed Anderson’s conviction and sentence. View "Anderson v. Mississippi" on Justia Law

Elmer Norwood appealed his conviction for aggravated domestic violence, claiming that his trial counsel was constitutionally ineffective for failing to introduce evidence that would have impacted his accuser’s credibility. Finding no merit to Norwood’s ineffective-assistance-of-counsel claim, the Mississippi Supreme Court affirmed Norwood’s conviction. View "Norwood v. Mississippi" on Justia Law

Todd and Rae Andreacchio sued Joel Wagner for intentional infliction of emotional distress, gross negligence, invasion of privacy, and civil conspiracy. Wagner published portions of the investigative file of their son’s death on the internet. The Mississippi Supreme Court found the investigative file was clearly was a public record that was furnished to Wagner by the Mississippi Attorney General’s Office, making Wagner’s publication of portions of the file constitutionally protected. Because the Andreacchios based all their claims on Wagner’s publication of legally obtained public information, their complaint against him failed as a matter of law. The Supreme Court therefore reversed the trial court’s ruling denying Wagner’s motion to dismiss and rendered judgment in Wagner’s favor, dismissing all claims against him. View "Wagner v. Andreacchio" on Justia Law