Watts v. State
78 So. 3d 901
| Miss. | 2012Background
- Watts was convicted of felony fleeing or eluding a law enforcement officer in a motor vehicle under Miss. Code § 97-9-72 and sentenced to five years with two suspended and three years post-release supervision.
- Watts argues double jeopardy because he previously pled guilty to misdemeanor reckless driving in Lauderdale County Justice Court for the same incident.
- In June 2008 Watts led officers at speeds of 100–135 mph after fleeing a roadblock; he crashed and fled on foot, not being apprehended.
- Watts signed a confession on June 10, 2008 admitting he fled the roadblock, was going over 100 mph, and fled on foot after the crash.
- Watts was indicted for felony fleeing on July 24, 2008; the indictment was not served until August 11, 2009, and he pled not guilty on August 24, 2009.
- On August 27, 2008 Watts pleaded guilty to reckless driving in justice court for the same June 1, 2008 incident; justice court lacked jurisdiction to adjudicate the felony charge.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether double jeopardy bars circuit court prosecution. | Watts argues double jeopardy bars circuit trial. | State argues lack of jeopardy because justice court lacked jurisdiction over felony charge. | Former jeopardy not implicated; justice court lacked jurisdiction to adjudicate the felony. |
| Whether enough evidence proves reasonable suspicion for felony fleeing. | Watts contends State failed to prove reasonable suspicion to believe he committed a crime. | State argues odor of alcohol supported reasonable suspicion and flight plus driving under influence. | Evidence sufficient to support conviction; odor testimony provided reasonable suspicion. |
| Whether Watts is entitled to relief based on ineffective assistance for not petitioning interlocutory review. | Watts claims ineffective assistance for not seeking interlocutory review. | State contends claim has no merit because the underlying issue lacks merit. | No reversible error; ineffective assistance claim without merit. |
Key Cases Cited
- Blockburger v. United States, 284 U.S. 299 (1932) (same-act test for multiple offenses)
- Butler v. State, 489 So.2d 1093 (Miss. 1986) (jurisdictional limits foreclose former jeopardy analysis)
- Chester v. State, 216 Miss. 748, 63 So.2d 99 (1953) (jurisdictional overlap permitting separate prosecutions)
- Smith v. State, 219 Miss. 741, 69 So.2d 837 (1954) (conviction in one court does not bar another in certain contexts)
- Loden v. State, 43 So.3d 365 (Miss. 2010) (ineffective assistance analysis standard)
- Harris v. State, 970 So.2d 151 (Miss. 2007) (cumulative error standard in Mississippi)