Jones v. State
122 So. 3d 725
| Miss. Ct. App. | 2011Background
- Jones killed his grandfather Bertis Jones during an August 2004 stabbing, later disposing of evidence and giving inconsistent statements.
- Trial evidence showed multiple stab wounds, defensive injuries, and dragging, with Jones claiming self-defense but the jury convicting him of murder.
- Jones waived Miranda rights and gave a statement; the statement was partially redacted and later challenged as involuntary.
- Jones was sentenced to life imprisonment; on direct appeal the conviction and sentence were affirmed.
- Jones pursued post-conviction relief arguing ineffective assistance of trial and appellate counsel, among other claims.
- Circuit court denied the PCR motion after an evidentiary hearing; Jones timely appealed challenging multiple trial-counsel decisions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was failure to move for mistrial deficient and prejudicial? | Jones | State | No deficiency; no prejudice |
| Was withdrawal of suppression motion ineffective assistance? | Jones | State | No prejudice; unlikely suppression would have succeeded |
| Did defense failure to investigate constitute deficient performance? | Jones | State | No deficiency; strategic decisions supported by record |
| Were witnesses Madge and Tony improperly omitted, or their failure prejudicial? | Jones | State | No deficient performance; strategic weighing of cross-examination risks |
| Did voir dire regarding juror relationships or prosecutorial remarks amount to ineffective assistance? | Jones | State | No Strickland prejudice; evidentiary and instruction context mitigated |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. Supreme Court 1984) (two-prong test for ineffective assistance; deference to strategy)
- Clemons v. State, 733 So.2d 266 (Miss. 1999) (age as factor in voluntariness; minor statements admissibility)
- In re W.R.A., 481 So.2d 280 (Miss. 1985) (voluntariness framework for confessions; Miranda waiver relevance)
- Moore v. State, 933 So.2d 910 (Miss. 2006) (Miranda voluntariness burdens evidence of voluntariness)
- Graham v. Florida, 560 U.S. 46 (U.S. Supreme Court 2010) (juvenile life without parole categorical restrictions contextually examined)
- Roper v. Simmons, 543 U.S. 551 (U.S. Supreme Court 2005) (juvenile sentencing norms; framework for proportionality analysis)
- Rowland v. State, 42 So.3d 503 (Miss. 2010) (standard of review for post-conviction facts; credibility determinations)