Howell v. Mississippi, 543 U.S. 440 (2005)
Primary Holding
The Supreme Court of the United States dismissed the writ of certiorari in Howell v. Mississippi, concluding that the petitioner failed to raise his claim regarding jury instructions on lesser included offenses in the state court, resulting in the claim not being addressed. Thus, the Court held that a failure to preserve a claim for appeal can lead to dismissal of that claim at the federal level.
In Howell v. Mississippi, the Supreme Court decided not to hear a case where Marlon Howell argued that he should have been given instructions about lesser charges (like manslaughter) during his trial for murder. The Court dismissed the case because Howell didn't bring up this issue in the state court, meaning he lost the chance to appeal it at the federal level. This case highlights the importance of properly raising all legal arguments during a trial. For consumers, it emphasizes the need to understand their rights and ensure that all possible defenses or claims are presented in court, or they risk losing them forever. If someone is facing legal issues, they should make sure to consult with a lawyer to avoid missing important steps that could affect their case.
AI-generated plain-language summary to help you understand this case
In the case of Howell v. Mississippi, Marlon Latodd Howell, also known as Marlon Cox, was convicted and sentenced to death for the murder of Hugh David Pernell. The incident occurred on May 15, 2000, when Pernell was delivering newspapers from his car. Howell, who was in another vehicle, approached Pernell's car after a brief conversation, during which a scuffle ensued. Howell then shot Pernell through the heart and fled the scene. At trial, Howell claimed he was in a different city at the time of the murder and argued that the evidence was insufficient to prove that the killing occurred during an attempted robbery, which is a necessary element for a capital murder charge. He sought jury instructions for lesser included offenses, specifically manslaughter and simple murder, but the trial court denied these requests. Following his conviction, Howell appealed to the Supreme Court of Mississippi, raising multiple claims of error, including the trial court's refusal to provide jury instructions on the lesser included offenses. He cited several cases regarding lesser-included-offense instructions, but the State Supreme Court ultimately affirmed his conviction and death sentence, concluding that the facts of the case did not support the requested instructions. The court referenced prior rulings indicating that such instructions should only be given if the evidence justifies them and would not cause the jury to ignore the primary charge of capital murder. Howell subsequently sought certiorari from the United States Supreme Court, arguing that the refusal to instruct the jury on lesser included offenses violated his rights under the Eighth and Fourteenth Amendments. However, the Supreme Court dismissed the writ of certiorari as improvidently granted, noting that Howell had not raised the jury instruction claim in the Mississippi Supreme Court, which had not addressed the issue.
Whether the refusal of the Mississippi courts to require a jury instruction on a lesser included offense in a capital case violates the Eighth and Fourteenth Amendments to the United States Constitution.
The writ of certiorari is dismissed as improvidently granted.
- Court
- Supreme Court
- Decision Date
- Unknown
- Jurisdiction
- federal
- Case Type
- landmark
- Damages Awarded
- N/A
- Data Quality
- high
Brown v. Payton, 544 U.S. 133 (2005)
Consumer LostThe Supreme Court held that the Ninth Circuit's decision granting habeas relief was contrary to the limits on federal habeas review imposed by 28 U.S.C. § 2254(d), affirming that the jury instructions in the penalty phase of Payton's trial were not constitutionally deficient and did not prevent the jury from considering all relevant mitigation evidence.
Bell v. Thompson, 545 U.S. 794 (2005)
Consumer LostThe Court of Appeals abused its discretion by withholding its mandate for more than five months after the denial of certiorari without entering a formal order.
Bell v. Cone, 543 U.S. 447 (2005)
Consumer LostThe Supreme Court held that the "especially heinous, atrocious, or cruel" aggravating circumstance used in sentencing was not unconstitutionally vague, and thus the state court's findings were entitled to deference under 28 U.S.C. § 2254(d).
Rompilla v. Beard, 545 U.S. 374 (2005)
Consumer LostEven when a capital defendant's family members and the defendant himself suggest that no mitigating evidence is available, defense counsel is required by the Sixth Amendment to make reasonable efforts to obtain and review material that the prosecution will likely use as evidence of aggravation during the sentencing phase of trial.