Jackson v. State
2011 Miss. LEXIS 368
| Miss. | 2011Background
- Jackson pled guilty to capital murder in 1979 in Warren County and was sentenced as a habitual offender to life without parole.
- He filed multiple post-conviction relief motions under UPCCRA beginning in 1986; the trial court dismissed his 1986 motion as time-barred, and this Court later held the UPCCRA limitations apply prospectively (Jackson I).
- On remand, the trial court and this Court handled subsequent PCR filings in the 1990s with additional denials and affirmations without substantive merits discussed here (Jackson II, Jackson III).
- In 1999, 2002, and 2004 Jackson sought leave in this Court to pursue PCR in the trial court; this Court denied those applications as impermissible successive writs.
- In 2007 Jackson filed a PCR motion in the Warren County Circuit Court; the circuit court dismissed as a successive writ; Court of Appeals affirmed.
- This Court granted certiorari, withdrew the previous opinion, substituted a new one, and held the Warren County Circuit Court should exercise initial jurisdiction; remanded for further PCR proceedings in the trial court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court or this Court has initial jurisdiction over Jackson's PCR motion | Jackson contends this Court had jurisdiction to address his dismissed PCR motions | State argues reaffirmed jurisdiction rules and procedural bars applied | This Court held the circuit court has initial jurisdiction and remanded for proceedings in the trial court |
| Whether the UPCCRA successive-writ bar barred Jackson's 2007 PCR motion | Jackson argues the denials were vacated and the bar does not apply | State maintains the successive-writ bar applies | The Court vacated its prior denials and remanded; the matter proceeds consistent with initial-jurisdiction holding |
| Whether Berryhill-related indictment defects affected post-conviction viability | Jackson claimed Berryhill invalidates the indictment or that it omitted required language | State argued indictment nonetheless charged a crime and Berryhill retroactivity not established | Court's retroactive impact on Berryhill and indictment defects unresolved; remand for PCR proceedings in trial court |
| Whether the trial court properly dismissed the petition under procedural bars after jurisdiction shift | Jackson argues dismissal errors under jurisdictional shift | State asserts proper application of procedural bars before remand | Remand for initial trial-court consideration;双方 to proceed with post-conviction-relief proceedings in trial court. |
Key Cases Cited
- Martin v. State, 556 So.2d 357 (Miss. 1990) (trial court holds exclusive jurisdiction for guilty pleas without direct appeal)
- McDonall v. State, 465 So.2d 1077 (Miss. 1985) (jurisdictional framework for post-conviction relief petitions)
- Odom v. State, 483 So.2d 343 (Miss. 1986) (prospective application of UPCCRA time bar)
- Jackson I, 506 So.2d 994 (Miss. 1987) (UPCCRA limitations apply prospectively)
- Jackson II, 568 So.2d 1212 (Miss. 1990) (appeals about remand and procedural posture of PCR)
- Jackson III, 665 So.2d 1356 (Miss. 1995) (subsequent PCR proceedings post-1990s)
- Berryhill, 703 So.2d 250 (Miss. 1997) (indictment-shell issues for capital-murder predicated on burglary)