Mississippi Commission on Judicial Performance v. Judge John H. Sheffield, 235 So. 3d 30

In 1996 James Harper was convicted in Lee County Justice Court for DUI and fined; he appealed the DUI to county court and the appeal notice was placed in the justice-court file. Harper later satisfied the county-court sentence.
In April 2013 Harper appeared before Justice Court Judge John H. Sheffield; despite Harper’s protests and the presence of the 1996 case file (which contained the notice of appeal and county-court notice), Sheffield sentenced Harper to six months at the Lee County Work Center.
Harper served about four months before release for a serious infection; the sentence was imposed though the justice court had been divested of jurisdiction by the earlier appeal and the county judgment had been satisfied.
The Mississippi Commission on Judicial Performance charged Sheffield with judicial misconduct; after a hearing the Commission recommended public reprimand, 120-day suspension without pay, a $3,000 fine, and assessment of costs.
The Supreme Court found clear and convincing evidence of misconduct (neglect/ignorance/incompetence), agreed the Canons of Judicial Conduct were violated, and imposed the recommended discipline: public reprimand, 120-day suspension without pay, $3,000 fine, and costs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Judge Sheffield committed judicial misconduct by incarcerating Harper despite an appeal and satisfied county sentence	Commission: Sheffield ignored the record and Harper’s assertion of appeal; his actions were negligent/contrary to judicial canons	Sheffield: claimed he searched the file and did not find the appeal notice; characterized lapse as inattention, not bad faith	Court: Held Sheffield committed misconduct—negligence/ignorance/incompetence violating Canons 1, 2A, 3B(2), 3B(4), 3B(8), 3C(1)
Whether the conduct was willful or merely negligent	Commission: Conduct showed gross unconcern; prior disciplinary history relevant to culpability	Sheffield: maintained the error was due to inattention and not intentional wrongdoing	Court: Treated conduct as negligent (not shown to be malicious), but aggravated by failure to accept responsibility and prior discipline
Appropriate sanction for illegal incarceration and misconduct	Commission: Recommended public reprimand, 120-day suspension without pay, $3,000 fine, costs	Sheffield: Argued sanctions should reflect inattention and his long service; Justice King (concurrence/dissent) argued removal was warranted	Court: Accepted Commission’s recommendation and imposed reprimand, 120-day suspension without pay, $3,000 fine, and assessed costs

Miss. Comm’n on Judicial Performance v. Littlejohn, 172 So.3d 1157 (Miss. 2015) (illegal incarceration as serious harm; prior sanctioning guidance)
Miss. Comm’n on Judicial Performance v. Darby, 75 So.3d 1037 (Miss. 2011) (discipline for wrongful detention where procedures were not followed)
Miss. Comm’n on Judicial Performance v. Dodds, 680 So.2d 180 (Miss. 1996) (removal warranted where judge knowingly acted beyond authority)
In re Bailey, 541 So.2d 1036 (Miss. 1989) (justice court judges’ role and need for strict adherence to judicial conduct)
Miss. Comm’n on Judicial Performance v. Sheffield, 883 So.2d 546 (Miss. 2004) (prior disciplinary history of same judge considered)