Justia Constitutional Law Opinion Summaries

On April 7, 2020, Matthew Wallace was hired by the Centreville Police Department, located in the Town of Centreville, Mississippi. In 2021, Wallace was dispatched with a Town of Centreville certified police officer, to a scene involving multiple juveniles riding all-terrain vehicles in the town limits. An altercation occurred; at some point during the altercation, Wallace went to the patrol unit to retrieve the police-issued pepper spray. Upon returning to the scene, Wallace released the pepper spray. Sometime following the incident, one of the juveniles and his mother filed charges against Wallace for simple assault on a minor. The issue presented for the Mississippi Supreme Court's review centered around a probable cause hearing pursuant to Mississippi Code Section 99-3-28. Before the hearing, the State petitioned the circuit court to determine whether Wallace was entitled to a probable cause hearing, alleging Wallace was not a sworn law enforcement officer. At the hearing, the circuit determined that Wallace was not a sworn law enforcement officer and, therefore, was not entitled to a probable cause hearing. Wallace moved the circuit court for a probable cause hearing for the same underlying incident. The circuit court denied the motion, finding, again, that Wallace was not a sworn law enforcement officer and, therefore, was not entitled to a probable cause hearing under Section 99-3-28. Wallace appealed. The Supreme Court held that a law enforcement officer who is not certified pursuant to Mississippi Code Section 45-6-11(3)(a) is not entitled to a probable cause hearing under Mississippi Code Section 99-3-28(1)(a)(i). Further, the Court held Wallace was not entitled to a probable cause hearing under Section 99-3-28(1)(a)(i) because he was not a law enforcement officer as defined by Mississippi Code Section 45-6-3(c). View "Wallace v. Mississippi" on Justia Law

Troy Eaton was convicted by jury of second-degree murder for the shooting and death of Josh Smith and of aggravated assault for the shooting of Ricky Dale Vick. On appeal, Eaton challenged the admission of a glass pipe into evidence, the sufficiency of the evidence, and the weight and credibility of the evidence. Finding no error, the Mississippi Supreme Court affirmed the convictions and sentences. View "Eaton v. Mississippi" on Justia Law

Samuel Anderson was convicted by jury of the murder of his grandmother, Evelyn Davenport. On appeal, Anderson argued the trial court erred by refusing an accident-or-misfortune jury instruction and by admitting evidence of Anderson’s other bad acts. Finding Anderson's claims lacked merit, the Mississippi Supreme Court affirmed. View "Anderson v. Mississippi" on Justia Law

Former City of Clarksdale Commissioner Charles Moton alleged that his December 2013 and May 2015 arrests at Clarksdale city commissioners meetings were in violation of "a litany" of his state constitutional rights. The trial court dismissed Moton’s claims because he failed to file suit within the statute of limitations. Finding no reversible error, the Mississippi Supreme Court affirmed the trial court's judgment. View "Moton v. City of Clarksdale" on Justia Law

David Sills was convicted of possession of methamphetamine greater than two grams but less than ten grams in violation of Mississippi Code Section 41-29-139 (Rev. 2018). Sills appealed, arguing: (1) the jury’s verdict was against the overwhelming weight of the evidence; (2) the State failed to meet its burden of proof regarding constructive possession; and (3) the trial court erred by denying Sills’ motion to suppress illegally obtained evidence. Finding no merit to either claim, the Mississippi Supreme Court affirmed Sills’ conviction. View "Sills v. Mississippi" on Justia Law

Wade Willard, Sr. was convicted by jury for possession of methamphetamine, for which he was sentenced to twelve years as a habitual offender. On direct appeal to the Mississippi Supreme Court, Willard argued the trial court erred in striking two potential jurors for cause and erred in limiting his cross examination of the arresting error. After review of the trial court record, the Supreme Court found no reversible error and affirmed Willard’s conviction and sentence. View "Willard v. Mississippi" on Justia Law

The Mississippi Baptist Foundation and various heirs of the decedent’s wife both claimed ownership over certain mineral interests devised in the decedent’s will at the time of the decedent’s death in 1969. The will left most of the estate, including the mineral interests, to the Mississippi Baptist Foundation as trustee, with income from the trust going to the decedent’s wife for life, then to his sister for life, and then to benefit the Mississippi Baptist Foundation’s foreign missions. In 1969, Mississippi had mortmain laws (repealed in 1992 and 1993), the relevant portion of which provided that after ten years in the possession of certain proscribed institutions, including religious institutions, real property reverted to the decedent’s heirs if the institution failed to sell the property within that ten-year time period. The Mississippi Baptist Foundation and the heirs disagreed as to when the ten-year period began in this case, and, if it applied, whether the mortmain laws were unconstitutional. The trial court found that the mortmain laws were triggered on the date of the decedent’s death in 1969 and that the mortmain laws were constitutional. Because the Mississippi Baptist Foundation had a possessory interest in the mineral interests in 1969, and because it failed to timely assert any claims regarding the property after it gained possession in 1969, the Mississippi Supreme Court affirmed the trial court. View "Mississippi Baptist Foundation v. Fitch, et al." on Justia Law

This case concerned the removal of two commissioners of the Canton Municipal Utilities Commission (CMU Commission) by the City of Canton Board of Aldermen (the Board). The Mayor of Canton vetoed a resolution of the Board issuing notice and an opportunity to be heard to the commissioners. The Board claimed to override the veto by a vote of two-thirds of the majority of members, although in actuality it failed for lack of the requisite majority. It then proceeded with a hearing and ultimately removed the commissioners from their appointed positions. The decision of the Board was appealed. The circuit court reversed the decision to remove the commissioners, finding that the Board failed to override the Mayor’s veto and that the actions taken to remove the commissioners following the failure to override the veto were void as a matter of law. The Board appealed to the Mississippi Supreme Court, claiming the commissioners’ notice of appeal contained fatal jurisdictional errors, notice and an opportunity to be heard were not required for the removal to be effective and the Board properly overrode the Mayor’s veto. After a careful review of the law, the Supreme Court affirmed the circuit court's judgment. View "City of Canton Board of Aldermen v. Slaughter, et al." on Justia Law

Lorenzo Manuel was convicted by jury of second-degree murder and aggravated assault. At sentencing, the trial judge found that Manuel was a habitual offender and sentenced him to forty years for second-degree murder and twenty years for aggravated assault. The judge ordered that these sentences were to run consecutively and without reduction, suspension, or possibility of parole. Manuel appealed, and the Mississippi Court of Appeal affirmed the trial court's judgment. The Mississippi Supreme Court granted Manuel’s petition for writ of certiorari to review the trial judge’s imposition of a habitual offender sentence. The Supreme Court found that the trial judge lacked sufficient evidence to sentence Manuel as a habitual offender. Additionally, the Court found that the Court of Appeals erred when it allowed the State to supplement the record with copies of the indictments for Manuel’s prior offenses. Therefore, the Court vacated Manuel’s habitual offender sentence and remanedd the case to the trial court to resentence Manuel as a nonhabitual offender. View "Manuel v. Mississippi" on Justia Law

Alberto Garcia confessed to raping and murdering five-year-old JT. He pled guilty to capital murder and waived jury sentencing. After a hearing, the trial judge sentenced Garcia to death. He appealed his sentence, and the Mississippi Supreme Court affirmed. He sought post-conviction relief from his sentence or leave to proceed in the trial court for further post-conviction proceedings. In his motion, Garcia argues his trial counsel provided constitutionally ineffective assistance. While he asserted his attorneys were deficient for three reasons, his primary claim was that counsel failed to pursue and present at the sentencing hearing evidence of fetal alcohol syndrome disorder (FASD) as a mitigating factor. After review, the Supreme Court found Garcia failed to present a substantial showing that his trial attorneys were deficient in investigating potential FASD, let alone that any prejudice resulted. "[T]here is no reasonable probability that FASD evidence would have caused the sentencing judge to find that the mitigators outweighed the aggravators, which included the heinous nature of Garcia’s crime." The Court likewise found Garcia failed to show deficiency and resulting prejudice on his other two ineffective-assistance-of-counsel claims. Therefore, his motion was denied. View "Garcia v. Mississippi" on Justia Law