Adam Lee Pinkton v. State of Mississippi

CourtCourt of Appeals of Mississippi
DecidedApril 15, 2025
Docket2024-CP-00655-COA
StatusPublished

This text of Adam Lee Pinkton v. State of Mississippi (Adam Lee Pinkton v. State of Mississippi) is published on Counsel Stack Legal Research, covering Court of Appeals of Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Adam Lee Pinkton v. State of Mississippi, (Mich. Ct. App. 2025).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2024-CP-00655-COA

ADAM LEE PINKTON APPELLANT

v.

STATE OF MISSISSIPPI APPELLEE

DATE OF JUDGMENT: 05/06/2024 TRIAL JUDGE: HON. CHARLES E. WEBSTER COURT FROM WHICH APPEALED: BOLIVAR COUNTY CIRCUIT COURT, FIRST JUDICIAL DISTRICT ATTORNEY FOR APPELLANT: ADAM LEE PINKTON (PRO SE) ATTORNEY FOR APPELLEE: OFFICE OF THE ATTORNEY GENERAL BY: BARBARA WAKELAND BYRD NATURE OF THE CASE: CIVIL - POST-CONVICTION RELIEF DISPOSITION: AFFIRMED - 04/15/2025 MOTION FOR REHEARING FILED:

BEFORE CARLTON, P.J., LAWRENCE AND EMFINGER, JJ.

LAWRENCE, J., FOR THE COURT:

¶1. On September 21, 2023, Adam Pinkton filed a motion for post-conviction collateral

relief (PCR) in the Bolivar County Circuit Court. The court denied the motion because it was

untimely, and, as part of his plea bargain agreement, he waived his right to file any motion

or other request for relief under the Mississippi Uniform Post-Conviction Collateral Relief

Act (UPCCRA). The court also found that Pinkton’s claims were meritless. Pinkton appealed

the denial. Upon review, we affirm.

FACTS AND PROCEDURAL HISTORY

¶2. On April 2, 1984, Adam Pinkton pled guilty to capital murder for killing a storekeeper after attempting to rob the store. On April 12, 1984, a jury imposed the death sentence on

Pinkton. Pinkton appealed his death sentence, and the Mississippi Supreme Court vacated

his sentence because the jury failed to make written findings in support of their imposition

of the death penalty, as required by Mississippi Code Annotated section 99-19-101(7) (Supp.

1983). The Mississippi Supreme Court reversed and remanded the case for re-sentencing.

Pinkton v. State, 481 So. 2d 306, 310 (Miss. 1985). Pinkton then entered into a plea bargain

agreement with the State, waiving his right to appeal his conviction and sentence or challenge

them under the UPPCRA.1 In return for those waivers, the State recommended that Pinkton

be sentenced to life imprisonment. On April 7, 1986, the circuit court accepted the plea

agreement and sentenced him to life imprisonment in the custody of the Mississippi

Department of Corrections.

¶3. Thirty-seven years later, on September 21, 2023, Pinkton filed a motion for PCR.

First, he claimed that his indictment was defective and insufficient because it failed to

include the essential element of “a human being.” Second, he claimed that his attorneys

rendered ineffective assistance of counsel because they failed to recognize the deficiency in

1 The plea bargain agreement stated, “The defendant hereby waives his right to a trial by jury during the sentencing phase, and hereby waives his right during the sentencing phase to the confrontation of witnesses, to his right of appeal from adverse rulings, verdict and adjudications, and the defendant specifically hereby waives his right to file any motion or other request for relief under the Mississippi Uniform Post-Conviction Collateral Relief Act, Miss. Code Ann. § 99-39-1 to -29 (Supp. 1985), specifically objecting to or complaining about the charge of capital murder and its underlying felony of armed robbery, and sentences for armed robbery, capital murder, and aggravated assault . . . .”

2 the indictment. Third, he argued that he was subjected to double jeopardy.

¶4. The circuit court denied Pinkton’s claim and dismissed his PCR motion because his

claims were time-barred, and he had waived his right to file any motion or other request for

relief under the UPCCRA the plea bargain agreement. Nevertheless, the circuit court

addressed each claim raised in Pinkton’s PCR motion and found that each claim was without

merit. Pinkton now appeals, arguing the same issues.

STANDARD OF REVIEW

¶5. When reviewing a circuit court’s decision to deny a PCR motion, this Court will not

disturb the circuit court’s factual findings unless they are found to be clearly erroneous.

Brown v. State, 731 So. 2d 595, 598 (¶6) (Miss. 1999) (citing Bank of Miss. v. S. Mem’l Park

Inc., 677 So. 2d 186, 191 (Miss. 1996)). When issues of law are raised, we apply a de novo

review. Rice v. State, 910 So. 2d 1163, 1164-65 (¶4) (Miss. Ct. App. 2005) (citing Brown,

731 So. 2d at 598 (¶6)).

ANALYSIS

¶6. Pinkton raises three issues on appeal. First, he claims that his indictment was defective

and insufficient because it failed to include the words “a human being,” which he argues is

an essential element. Second, he claims that his attorneys rendered ineffective assistance of

counsel because they failed to recognize the deficiency in the indictment. Third, he argues

that he was subjected to double jeopardy.

¶7. A defendant who pleads guilty to a charge and later files a PCR motion under the

3 UPCCRA must file it within three years after the judgment of conviction. The Mississippi

Supreme Court has made clear that an untimely PCR motion is barred if it is filed beyond the

three-year time period unless the claim fits within one of the express statutory exceptions.

Howell v. State, 358 So. 3d 613, 615-16 (¶¶8, 12) (Miss. 2023). The statutory exceptions to

the three-year time-bar are for (1) an intervening decision of the Mississippi Supreme Court

or United States Supreme Court that “would have actually adversely affected the outcome

of his conviction or sentence,” (2) newly discovered evidence that is “of such nature that it

would be practically conclusive” that it would have caused a different outcome if introduced

at trial, (3) the testing of certain biological evidence, (4) claims that the movant’s “sentence

has expired or his probation, parole or conditional release has been unlawfully revoked,” and

(5) certain motions for relief in cases where the death penalty is imposed. Miss. Code Ann.

§§ 99-39-5(2) & -23(6) (Rev. 2020).

¶8. In April 1986, Pinkton was re-sentenced for his 1984 capital murder conviction. Yet

his PCR motion was filed over thirty-seven years later in September 2023. His claims for

ineffective assistance of counsel, a defective indictment, and double jeopardy are not

statutory exceptions to the time-bar. The circuit court correctly determined that Pinkton’s

motion was time-barred.

¶9. Notwithstanding that his PCR was time-barred, we will address the merits of his

claims, which are all legally insufficient to set aside his plea or sentence. First, he argues that

the indictment charging him with capital murder was defective and insufficient because of

4 its failure to include the words “a human being” when describing the victim. “[C]hallenges

to the substantive sufficiency of an indictment may not be waived and consequently may be

raised for the first time on appeal.” Ross v. State, 954 So. 2d 968, 1015 (¶126) (Miss. 2007)

(quoting State v. Berryhill, 703 So. 2d 250, 254 (Miss. 1997)). However, a defendant’s “valid

guilty plea . . . waives all nonjurisdictional defects or insufficiencies in the indictment.”

Scurlock v.

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Related

White v. State
532 So. 2d 1207 (Mississippi Supreme Court, 1988)
Pinkton v. State
481 So. 2d 306 (Mississippi Supreme Court, 1985)
Ross v. State
954 So. 2d 968 (Mississippi Supreme Court, 2007)
Bank of Mississippi v. SOUTHERN MEMORIAL PARK, INC.
677 So. 2d 186 (Mississippi Supreme Court, 1996)
Coffield v. State
749 So. 2d 215 (Court of Appeals of Mississippi, 1999)
Edwards v. State
441 So. 2d 84 (Mississippi Supreme Court, 1983)
State v. Berryhill
703 So. 2d 250 (Mississippi Supreme Court, 1997)
Bullock v. State
525 So. 2d 764 (Mississippi Supreme Court, 1987)
Dycus v. State
440 So. 2d 246 (Mississippi Supreme Court, 1983)
Brown v. State
731 So. 2d 595 (Mississippi Supreme Court, 1999)
Reddix v. State
547 So. 2d 792 (Mississippi Supreme Court, 1989)
Rice v. State
910 So. 2d 1163 (Court of Appeals of Mississippi, 2005)
Wheeler v. State
536 So. 2d 1341 (Mississippi Supreme Court, 1988)
Coleman v. State
378 So. 2d 640 (Mississippi Supreme Court, 1979)
Joiner v. State
61 So. 3d 156 (Mississippi Supreme Court, 2011)
Frederick Emanuel Scurlock v. State of Mississippi
147 So. 3d 894 (Court of Appeals of Mississippi, 2014)
Kevin Thomas v. State of Mississippi
159 So. 3d 1212 (Court of Appeals of Mississippi, 2015)
Kelly v. State
80 So. 3d 802 (Mississippi Supreme Court, 2012)
Cox v. State
134 So. 3d 712 (Mississippi Supreme Court, 2014)
Bell v. State
207 So. 3d 705 (Court of Appeals of Mississippi, 2016)

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