London Williams, Jr. v. State of Mississippi
228 So. 3d 381
| Miss. Ct. App. | 2017Background
- London Williams was convicted of incest under Miss. Code Ann. § 97-29-5 for sexual activity with his daughter (who was 20) and acquitted of sexual battery.
- The Sunflower County Circuit Court sentenced Williams to ten years in MDOC custody, with four years suspended and four years of post-release supervision.
- MDOC classified incest as a “sex crime,” rendering Williams ineligible for parole or earned time under relevant statutes; MDOC denied his administrative challenge.
- Williams argued that incest, while sexual in nature, is not a statutory “sex crime” and appealed the administrative denial to the circuit court and then to this Court, which both cited Cochran v. State in support of the classification.
- While the appeal was pending in this Court, Williams was released on post-release supervision; the Court held the appeal moot because a favorable ruling would confer no practical benefit.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether incest qualifies as a "sex crime" for MDOC purposes | Williams: incest is not a statutory "sex crime" and should not trigger parole/earned-time ineligibility | MDOC/State: incest is a sex crime (per Cochran), making inmate ineligible for parole/earned time | Court did not decide on merits — appeal dismissed as moot due to Williams' release |
| Whether MDOC's classification can be reviewed while inmate on post-release supervision | Williams: review remains necessary to correct classification | State: classification stands; practical relief unavailable after release | Court: no practical relief possible post-release; case moot |
| Applicability of sex-offender registration definitions to classification dispute | Williams: incest not listed in § 45-33-23(h), so not a sex offense | State: registration definition controls only registration chapter; doesn't resolve MDOC classification | Court: noted distinction in a footnote but did not decide due to mootness |
| Whether prior appellate precedent controls MDOC classification | Williams: challenges Cochran's application | State: Cochran governs and supports MDOC policy | Court relied on existing precedent in lower proceedings but dismissed appeal as moot without overruling Cochran |
Key Cases Cited
- Williams v. State, 89 So. 3d 676 (Miss. Ct. App. 2012) (underlying criminal case discussing facts of Williams' convictions)
- Cochran v. State, 969 So. 2d 119 (Miss. Ct. App. 2007) (held that incest is a sex crime for MDOC classification)
- Fails v. Jefferson Davis Cty. Pub. Sch. Bd., 95 So. 3d 1223 (Miss. 2012) (standing/mootness principles requiring practical benefit for appellate relief)
- Hunt v. Mississippi Dep’t of Corr., 217 So. 3d 789 (Miss. Ct. App. 2017) (affirming mootness where no practical relief available after release)