Corrothers v. State
189 So. 3d 612
| Miss. | 2015Background
- Caleb Corrothers was convicted in Lafayette County Circuit Court of two counts of capital murder and sentenced to death; convictions affirmed by the Mississippi Supreme Court in Corrothers v. State, 148 So.3d 278 (Miss. 2014).
- Post‑conviction counsel appointed; under M.R.A.P. 22(c)(4) Corrothers moved in circuit court for discovery to obtain Youth Court and Mississippi Department of Human Services (DHS) records and local news videotapes to support a forthcoming post‑conviction petition.
- The State moved for reciprocal discovery seeking access to any materials Corrothers obtained (videos, youth court records, DHS records); the circuit court granted both motions on June 3, 2015.
- Corrothers petitioned this Court for interlocutory review, arguing Rule 22 does not authorize reciprocal discovery to the State prior to the filing of a post‑conviction petition.
- The Supreme Court granted interlocutory appeal and vacated the circuit court’s order to the extent it provided the State reciprocal access to local news videotapes, youth court records of Corrothers and his siblings, and family DHS records.
Issues
| Issue | Corrothers' Argument | State's Argument | Held |
|---|---|---|---|
| Whether M.R.A.P. 22 authorizes reciprocal discovery to the State before a post‑conviction petition is filed | Rule 22 allows discovery only to petitioners preparing post‑conviction pleadings; it contains no provision granting the State reciprocal discovery | The State sought reciprocal discovery to inspect materials Corrothers obtained and to defend against any eventual petition | Court held Rule 22 does not authorize the State to obtain reciprocal discovery prior to the filing of a post‑conviction petition and vacated that portion of the circuit court’s order |
| Whether interlocutory review of the circuit court’s reciprocal‑discovery order was appropriate | Corrothers sought review to prevent premature disclosure to the State | The State defended the circuit court order and sought to preserve access | Court granted interlocutory appeal, exercised review (noting de novo/legal issue and abuse‑of‑discretion standard for discovery), and resolved the reciprocal‑discovery question; separate justices objected that review may be unripe or deserved fuller briefing |
Key Cases Cited
- Corrothers v. State, 148 So.3d 278 (Miss. 2014) (prior direct‑appeal affirmance of convictions)
- Ford Motor Co. v. Tennin, 960 So.2d 379 (Miss. 2007) (discovery rulings reviewed for abuse of discretion)
- Moore v. State, 986 So.2d 928 (Miss. 2008) (questions of law reviewed de novo)
- Russell v. State, 819 So.2d 1177 (Miss. 2001) (Rule 22 permits petitioner discovery and compulsory process; ex parte discovery limited)
- Brown v. State, 88 So.3d 726 (Miss. 2012) (Rule 22 intended to allow petitioner to gather information to support an application for leave to file post‑conviction relief)