Mississippi Code

Miss. Code Ann. § 97-3-31 (2026)

Homicide; killing unnecessarily, while resisting effort of slain to commit felony or do unlawful act

✓ current as of July 2026
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Every person who shall unnecessarily kill another, either while resisting an attempt by such other person to commit any felony, or to do any unlawful act, or after such attempt shall have failed, shall be guilty of manslaughter.

Codes, Hutchinson's 1848, ch. 64, art. 12, Title 3 (11); 1857, ch. 64, art. 175; 1871, § 2638; 1880, § 2886; 1892, § 1159; 1906, § 1237; Hemingway's 1917, § 967; 1930, § 995; 1942, § 2225.


Notes of Decisions
Cited in 21 cases (2 in the last 5 years), 1974–2026 · leading case: May v. State, 460 So. 2d 778 (Miss. 1984).
May v. State, 460 So. 2d 778 (Miss. 1984). · cites it 14× “On October 18, 1982, the case was called for trial in the Circuit Court of Rankin County, Mississippi, at the conclusion of which the jury found May guilty of the lesser-included offense of manslaughter, Miss. Code Ann. § 97-3-31 (1972). The Circuit Court has sentenced May to a…”
James C. Newell, Jr. v. State of Mississippi, 175 So. 3d 1260 (Miss. 2015). · cites it 22× “” Miss. Code Ann. § 97-3-31 (Rev. 2014). Instruction S-4 required the jury to find that Newell killed Boyette unnecessarily while Boyette was committing an unlawful act, which follows the language of Section 97-3- 31.”
Neese v. State, 993 So. 2d 837 (Miss. Ct. App. 2008). · cites it 19× “" Miss. Code Ann. § 97-3-31 . Additionally, unlike the majority's suggestion that self-defense and manslaughter are mutually exclusive, the theories of unlawful — act manslaughter and self-defense may be alternatively pled with the line of demarcation being whether the jury…”
Wells v. State, 305 So. 2d 333 (Miss. 1974). · cites it 12× “" Miss. Code Ann. § 97-3-31 (1972). This section is applicable here because, if in fact it were unnecessary for the defendant to kill the deceased, the defendant was resisting an attack by the deceased.”
Buchanan v. State, 567 So. 2d 194 (Miss. 1990). · cites it 6× “Miss. Code Ann. § 97-3-31 (1972) provides: Every person who shall unnecessarily kill another, either while resisting an attempt by such other person to commit any felony, or to do any unlawful act, or after such attempt shall have failed, shall be guilty of manslaughter.”
Mease v. State, 539 So. 2d 1324 (Miss. 1989). · cites it 2× “The manslaughter instructions sought by the defense seem directed to unlawful act manslaughter under Section 97-3-31 and heat of passion manslaughter under Section 97-3-35.”
Faraga v. State, 514 So. 2d 295 (Miss. 1987). · cites it 2× “1986)] and manslaughter [ Miss. Code Ann. § 97-3-31 et seq. (1972)] would be deemed merged into the capital murder.”
Robinson v. State, 773 So. 2d 943 (Miss. Ct. App. 2000). · cites it 8× “See Miss.Code Ann. § 97-3-31 (Rev.1994). ¶ 36.”
Lott v. State, 597 So. 2d 627 (Miss. 1992). · cites it 2× “. do some great personal injury... ." Miss.”
Westbrook v. State, 29 So. 3d 828 (Miss. Ct. App. 2009). · cites it 2× “Mississippi Code Annotated section 97-3-31 (Rev.2006) states that an “unnecessary killing, either while resisting an attempt by such other person to commit any felony, or to do any unlawful act, or after such attempt shall have failed,” is manslaughter.”
Edge v. State, 393 So. 2d 1337 (Miss. 1981). · cites it 2× “The appellant argues that he was justified in shooting Murphy in defense of his wife whose life was being threatened. Mississippi Code Annotated section 97-3-15 (1972).”
Johnson v. Thigpen, 623 F. Supp. 1121 (S.D. Miss. 1985). · cites it 2× “§ 97-3-31. Petitioner did not testify at trial.”
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