Knight v. State
72 So. 3d 1056
| Miss. | 2011Background
- Knight was convicted of possession of cocaine with intent to distribute while in possession of a firearm in Pearl River County Circuit Court.
- Evidence at trial included drugs, cash, and a sawed-off shotgun found under a couch cushion during a search warrant execution.
- Shoemake testified she bought crack cocaine from Knight at his home; Case testified Knight was asleep on the couch when police arrived.
- Knight challenged the search warrant’s probable cause and his counsel’s handling of the warrant issue, plus demanded suppression or post-trial relief.
- The circuit court denied JNOV and a new trial; Knight timely appealed, raising ineffective assistance, sufficiency, and weight-of-the-evidence claims.
- The Mississippi Supreme Court dismissed the ineffective-assistance claim without prejudice and affirmed on the remaining issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance of counsel | Knight asserts counsel failed to investigate probable cause and to challenge the warrant. | Knight contends counsel stipulated to sufficiency, hindering suppression. | Dismissed without prejudice; record insufficient to decide on direct appeal. |
| Sufficiency of the evidence to prove constructive possession | State contends evidence shows Knight knowingly possessed drugs, money, and firearm. | Knight argues drugs may have belonged to Case or Shoemake; no sole possession shown. | Evidence sufficient; jury could find constructive possession and intent to distribute. |
| Weight of the evidence | State contends credibility issues are for the jury; verdict not against the weight of evidence. | Shoemake and Case unreliable; pleas and inconsistencies undermine verdict. | No reversal; weight of the evidence supports the conviction. |
Key Cases Cited
- Petti v. State, 666 So.2d 754 (Miss. 1995) (probable cause requires facts supporting fair belief in crime and involvement)
- Barrett v. Miller, 599 So.2d 559 (Miss. 1992) (probable cause evidenced by affidavit presented to magistrate)
- Roach v. State, 7 So.3d 911 (Miss. 2009) (reviewing warrants under totality of circumstances)
- Turner v. State, 3 So.3d 742 (Miss. 2009) (credibility determinations are for the jury)
- Bush v. State, 895 So.2d 836 (Miss. 2005) (standard for evaluating directed-verdict and JNOV)
- Dixon v. State, 953 So.2d 1108 (Miss. 2007) (constructive-possession framework and evidence evaluation)
- Curry v. State, 249 So.2d 414 (Miss. 1971) (possession elements and proximity considerations)
- Leatherwood v. State, 473 So.2d 964 (Miss. 1985) (role of surrounding circumstances in possession analysis)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (ineffective-assistance standard: deficient performance and prejudice)