Mikeal Ray Hollis v. State of Mississippi, 320 So.3d 518

At a Leake County safety checkpoint on April 30, 2018, deputies stopped Mikeal Hollis for an expired driver’s license and had him exit his vehicle.
During a pat-down, deputies discovered a bag of marijuana on Hollis; he was handcuffed and officers conducted a search incident to arrest and an inventory search of the vehicle.
Deputy Ogletree found a clear plastic container in the center console; Deputy Malone collected it and later transported it to the evidence locker and the crime lab; lab testing showed .23 gram of methamphetamine.
Two body‑camera videos were played at trial; one (introduced by the State) showed the car search and discovery of the meth; Ogletree’s bodycam footage was not retained per department policy.
Hollis moved to suppress the meth on Fourth Amendment and chain‑of‑custody grounds; the trial court denied suppression and overruled a Confrontation Clause objection related to Deputy Malone’s absence.
Appellate counsel filed a Lindsey brief finding no arguable issues; Hollis filed a terse pro se supplemental brief raising vague claims; the Supreme Court reviewed the record and affirmed the conviction.

Issue	Hollis' Argument	State's Argument	Held
Legality of search / inventory search	Search of vehicle was unlawful; suppression warranted	Search was a valid inventory search following arrest for possession of marijuana	Denied — trial court properly treated search as inventory and denial of suppression affirmed
Chain of custody for meth evidence	Chain broken because Deputy Malone (who transported item) did not testify	State not required to call every custodian; no evidence of tampering	Denied — no reasonable inference of tampering; chain sufficiently established
Confrontation Clause (Deputy Malone/testimonial statements)	Right to confront absent witness and cross‑examine; out‑of‑court statements used against him	No testimonial hearsay from Malone was offered, so Crawford does not apply	Denied — no Crawford violation because no testimonial statements were admitted
Alleged destruction/spoliation of bodycam footage	Ogletree’s video was destroyed; loss prejudiced defense	No claim raised at trial; no showing of apparent exculpatory value or bad faith	Denied / procedurally barred — spoliation not preserved and three‑part test not met
Conflicting witness testimony	Deputies contradicted each other about who handcuffed Hollis	Conflicts go to credibility for the jury	Denied — credibility conflicts are jury questions

Lindsey v. State, 939 So. 2d 743 (Miss. 2005) (procedure when appellate counsel finds no arguable issues)
Crawford v. Washington, 541 U.S. 36 (2004) (Confrontation Clause bars admission of testimonial statements by absent witnesses)
Deeds v. State, 27 So. 3d 1135 (Miss. 2006) (chain‑of‑custody principles and when absence of a custodian is permissible)
Conners v. State, 92 So. 3d 676 (Miss. 2012) (application of Crawford in Mississippi prosecutions)
Freeman v. State, 121 So. 3d 888 (Miss. 2013) (spoliation standard and Trombetta/Youngblood framework)
California v. Trombetta, 467 U.S. 479 (1984) (duty to preserve evidence with apparent exculpatory value)
Arizona v. Youngblood, 488 U.S. 51 (1988) (bad‑faith requirement for destruction of potentially useful evidence)
Swinney v. State, 241 So. 3d 599 (Miss. 2018) (procedural bar for issues not raised below)
Randolph v. State, 852 So. 2d 547 (Miss. 2002) (appellant’s duty to support arguments with reasons and authorities)