newly discovered evidence exception (Mississippi) · Go Syfert
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newly discovered evidence exception in Mississippi

13 Mississippi opinions name it 2 courts 2004–2024 4 in the last five years

The cases below were cited by Mississippi courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
Chancy v. Stategreen
miss · 2006 · cited in 3 Mississippi opinions naming this issue, 2007–2022
2 sentences

2022Chancy v. State, 938 So. 2d 251, 252-53 (¶4) (Miss. 2006); accord Huggins v. State, 291 So. 3d 401 , 403-04 (¶6) (Miss.

2016Chancy v. State, 938 So. 2d 251, 252-253 (¶4) (Miss. 2006).

33
Ronk v. Stategreen
miss · 2015 · cited in 1 Mississippi opinions naming this issue, 2024–2024
1 sentence

2024Ronk I, 172 So. 3d at 1121, 1123, 1133, 1148 . (7) Ronk’s claim that counsel were ineffective for failing to seek funds to hire a neuropsychologist to present mitigating evidence of his history of neurological dysfunction, bipolar disorder, and attention deficit with hyperactivity disorder (ADHD) is neither sufficient to surmount the bars nor satisfies the newly-discovered-evidence exception. ¶113.

11
Jackson v. Stategreen
miss · 2007 · cited in 1 Mississippi opinions naming this issue, 2023–2023
1 sentence

2023Id.; see also Jackson v. State, 965 So. 2d 686, 689 (¶9) (Miss. 2007) (recognizing the holding in Chancy- SCT “that in the case of newly discovered evidence, post-conviction relief is available even where an individual pleaded guilty and untimely filed the petition for post-conviction relief”) (emphasis added)).

11
Crawford v. Stategreen
miss · 2003 · cited in 1 Mississippi opinions naming this issue, 2023–2023
2 sentences

2023Finally, Powers argues that the notated venire lists satisfy the newly-discovered- evidence exception—i.e., “(1) [they] w[ere] discovered after the trial; (2) [they] could not by due diligence have been discovered before trial; (3) [they] [are] material to the issue and not merely cumulative or impeaching; and (4) [they] would probably produce a different result or verdict in the new trial,” Brown, 306 So. 3d at 744 (citing Crawford v. State, 867 So. 2d 196 , 203–04 (Miss. 2003))—and that the Court has never “squarely” or “fully” addressed that evidence.

2023See Brown, 306 So. 3d at 744 (stating that the new evidence must be material and “not merely cumulative or impeaching”(citing Crawford, 867 So. 2d at 203–04)).

11
Willie James Allen v. State of Mississippigreen
missctapp · 2014 · cited in 1 Mississippi opinions naming this issue, 2018–2018
1 sentence

2018Allen , 177 So.3d at 1151 (¶ 6) ; see also Miss.

11
Kenneth Blake Watkins v. State of Mississippigreen
missctapp · 2014 · cited in 1 Mississippi opinions naming this issue, 2016–2016
1 sentence

2016“Relief must be denied if the movant fails to meet' any one of these four elements.” Id.; see also Watkins, 170 So.3d at 587-88 (¶ 20) (In order “[t]o prevail on a newly-discovered-evidence claim, [Kidd] had to show evidence that is both newly discovered and material to the outcome of his convictions.”).. ¶ 10.

11
McCoy v. Stategreen
missctapp · 2012 · cited in 1 Mississippi opinions naming this issue, 2014–2014
1 sentence

2014To prevail on a newly-discovered-evidence claim, Watkins had to show “evidence that is both newly discovered and material to the out *588 come of his convictions.” McCoy v. State, 111 So.3d 673, 676 (¶8) (Miss.Ct.App.2012). ¶ 21.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Mississippi. Read the followed side critically anyway.

Also cited on this issue (10)

CaseCitedYears
Sykes v. State green
missctapp · 2005
2 sentences

2007The Court of Appeals itself also recognized the newly discovered evidence exception in the context of guilty pleas in the following cases: Gaston v. State, 922 So.2d 841 (Miss.Ct.App.2006); Sykes v. State, 919 So.2d 1064 (Miss.Ct. *690 App.2005); Garlotte v. State, 915 So.2d 460 (Miss.Ct.App.2005); Freshwater v. State, 914 So.2d 328 (Miss.Ct.App.2005); McGriggs v. State, 877 So.2d 447 (Miss.

2006The Court of Appeals itself also recognized the newly discovered evidence exception in the context of guilty pleas in the following cases: Gaston v. State, 922 So.2d 841 (Miss.Ct.App.2006); Sykes v. State, 919 So.2d 1064 (Miss.Ct.

42004–2007
Gaston v. State green
missctapp · 2006
2 sentences

2007The Court of Appeals itself also recognized the newly discovered evidence exception in the context of guilty pleas in the following cases: Gaston v. State, 922 So.2d 841 (Miss.Ct.App.2006); Sykes v. State, 919 So.2d 1064 (Miss.Ct. *690 App.2005); Garlotte v. State, 915 So.2d 460 (Miss.Ct.App.2005); Freshwater v. State, 914 So.2d 328 (Miss.Ct.App.2005); McGriggs v. State, 877 So.2d 447 (Miss.

2006The Court of Appeals itself also recognized the newly discovered evidence exception in the context of guilty pleas in the following cases: Gaston v. State, 922 So.2d 841 (Miss.Ct.App.2006); Sykes v. State, 919 So.2d 1064 (Miss.Ct.

42004–2007
Freshwater v. State green
missctapp · 2005
2 sentences

2007The Court of Appeals itself also recognized the newly discovered evidence exception in the context of guilty pleas in the following cases: Gaston v. State, 922 So.2d 841 (Miss.Ct.App.2006); Sykes v. State, 919 So.2d 1064 (Miss.Ct. *690 App.2005); Garlotte v. State, 915 So.2d 460 (Miss.Ct.App.2005); Freshwater v. State, 914 So.2d 328 (Miss.Ct.App.2005); McGriggs v. State, 877 So.2d 447 (Miss.

2006App.2005); Garlotte v. State, 915 So.2d 460 (Miss.Ct.App.2005); Freshwater v. State, 914 So.2d 328 (Miss.Ct.App.2005); McGriggs v. State, 877 So.2d 447 (Miss.Ct.

22006–2007
McGriggs v. State green
missctapp · 2003
2 sentences

2007The Court of Appeals itself also recognized the newly discovered evidence exception in the context of guilty pleas in the following cases: Gaston v. State, 922 So.2d 841 (Miss.Ct.App.2006); Sykes v. State, 919 So.2d 1064 (Miss.Ct. *690 App.2005); Garlotte v. State, 915 So.2d 460 (Miss.Ct.App.2005); Freshwater v. State, 914 So.2d 328 (Miss.Ct.App.2005); McGriggs v. State, 877 So.2d 447 (Miss.

2006App.2005); Garlotte v. State, 915 So.2d 460 (Miss.Ct.App.2005); Freshwater v. State, 914 So.2d 328 (Miss.Ct.App.2005); McGriggs v. State, 877 So.2d 447 (Miss.Ct.

22006–2007
Garlotte v. State green
missctapp · 2005
2 sentences

2007The Court of Appeals itself also recognized the newly discovered evidence exception in the context of guilty pleas in the following cases: Gaston v. State, 922 So.2d 841 (Miss.Ct.App.2006); Sykes v. State, 919 So.2d 1064 (Miss.Ct. *690 App.2005); Garlotte v. State, 915 So.2d 460 (Miss.Ct.App.2005); Freshwater v. State, 914 So.2d 328 (Miss.Ct.App.2005); McGriggs v. State, 877 So.2d 447 (Miss.

2006App.2005); Garlotte v. State, 915 So.2d 460 (Miss.Ct.App.2005); Freshwater v. State, 914 So.2d 328 (Miss.Ct.App.2005); McGriggs v. State, 877 So.2d 447 (Miss.Ct.

22006–2007
Harrington v. Richter green
scotus · 2011
2 sentences

2024“Strickland d[id] not enact Newton’s third law for the presentation of evidence, requiring for every prosecution expert an equal and opposite expert from the defense.” Harrington v. Richter, 562 U.S. 86, 111 , 131 S. Ct. 770 , 178 L.

2024“Strickland d[id] not enact Newton’s third law for the presentation of evidence, requiring for every prosecution expert an equal and opposite expert from the defense.” Harrington v. Richter, 562 U.S. 86, 111 , 131 S. Ct. 770 , 178 L.

12024–2024
Strickland v. Washington green
scotus · 1984
1 sentence

2024Still more, given our adherence to the one-continuous-transaction doctrine, there is no reasonable probability that 27 Dr. Lauridson’s testimony would have affected Ronk’s capital-murder conviction. (3) Ronk’s claim that counsel were ineffective for failing to impeach Dr. McGarry’s testimony about the carbon-monoxide level in Craite’s blood and her being burned alive is neither sufficient to surmount the bars nor satisfies the newly-discovered-evidence exception. ¶74. “[C]ounsel has a duty to make reasonable investigations or to make a reasonable decision that makes particular investigations u

12024–2024
Brady v. Maryland green
scotus · 1963
2 sentences

2024And as the State notes, the GPMC Report flagged Craite’s 5.5 “CARBOXY HGB” result as “CH.” Though the meaning of “CH” is unclear, either the prosecution, Dr. McGarry, or both could have argued (as the State does here) that “CH” meant “Critical High.” And as discussed already, the GPMC Report was not the only evidence relevant to whether Craite was alive during the fire. (4) Ronk’s claim that the State suppressed material information about Dr. McGarry’s past is barred; his related ineffective-assistance-of-post- conviction counsel claim is insufficient to surmount the bars; and the newly-discov

2024And as the State notes, the GPMC Report flagged Craite’s 5.5 “CARBOXY HGB” result as “CH.” Though the meaning of “CH” is unclear, either the prosecution, Dr. McGarry, or both could have argued (as the State does here) that “CH” meant “Critical High.” And as discussed already, the GPMC Report was not the only evidence relevant to whether Craite was alive during the fire. (4) Ronk’s claim that the State suppressed material information about Dr. McGarry’s past is barred; his related ineffective-assistance-of-post- conviction counsel claim is insufficient to surmount the bars; and the newly-discov

12024–2024
Donnelly v. State green
missctapp · 2003
1 sentence

2007Ct.App.2003); Donnelly v. State, 841 So.2d 207 (Miss.Ct.App.2003); Wright v. State, 821 So.2d 141 (Miss.Ct.App.2000). ¶ 10.

12007–2007
Wright v. State neutral
missctapp · 2000
1 sentence

2007Ct.App.2003); Donnelly v. State, 841 So.2d 207 (Miss.Ct.App.2003); Wright v. State, 821 So.2d 141 (Miss.Ct.App.2000). ¶ 10.

12007–2007

Statutes the citing opinions construe

MS § Miss. Code Ann. § 99-39-5 (9) MS § Miss. Code Ann. § 99-39-23 (5) MS § Miss. Code Ann. § 97-3-79 (3) MS § Miss. Code Ann. § 99-39-21 (3) MS § Miss. Code Ann. § 99-39-9 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

FL 151 (1992–2026) PA 115 (2001–2026) MN 61 (2001–2026) WI 48 (1991–2026) IA 22 (1979–2026) WA 15 (2006–2025) MS 13 (2004–2024) NJ 10 (1982–2026) IL 8 (1996–2022) TN 8 (1996–2026) WV 8 (1979–2024) AL 7 (1987–2022) UT 7 (2005–2017) IN 6 (1980–2012) NY 5 (1980–2019) AZ 4 (1993–2022) KS 4 (1995–2021) DC 3 (1985–2000) CT 3 (2003–2023) MA 3 (1984–2015) OH 3 (1998–2016) MI 3 (2014–2015) NH 2 (2002–2015) TX 2 (1945–2005) MO 2 (2013–2013) CO 2 (2014–2025) ID 2 (2017–2020) GA 2 (1995–1996) ND 2 (2015–2016)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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