Beth Ann White v. State of Mississippi

CourtCourt of Appeals of Mississippi
DecidedFebruary 3, 2026
Docket2024-KA-00658-COA
StatusPublished

This text of Beth Ann White v. State of Mississippi (Beth Ann White 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
Beth Ann White v. State of Mississippi, (Mich. Ct. App. 2026).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2024-KA-00658-COA

BETH ANN WHITE APPELLANT

v.

STATE OF MISSISSIPPI APPELLEE

DATE OF JUDGMENT: 05/15/2024 TRIAL JUDGE: HON. WINSTON L. KIDD COURT FROM WHICH APPEALED: HINDS COUNTY CIRCUIT COURT, FIRST JUDICIAL DISTRICT ATTORNEY FOR APPELLANT: KEVIN DALE CAMP ATTORNEY FOR APPELLEE: OFFICE OF THE ATTORNEY GENERAL BY: BARBARA WAKELAND BYRD DISTRICT ATTORNEY: JODY EDWARD OWENS II NATURE OF THE CASE: CRIMINAL - FELONY DISPOSITION: AFFIRMED IN PART; REVERSED AND RENDERED IN PART; REMANDED - 02/03/2026 MOTION FOR REHEARING FILED:

BEFORE BARNES, C.J., WEDDLE AND LASSITTER ST. PÉ, JJ.

LASSITTER ST. PÉ, J., FOR THE COURT:

¶1. Beth Ann White was convicted in Hinds County of four counts of aggravated driving

under the influence (DUI) and one count of fourth-offense DUI. The circuit court sentenced

White to serve twenty-five years for each aggravated DUI conviction and ten years for her

fourth-offense DUI conviction, with all sentences to run consecutively. White appealed,

arguing that the State’s prosecution began after the statute of limitations on her offenses had

expired, that the prosecution was barred by double jeopardy, and that the State committed

prosecutorial misconduct. ¶2. After review, we hold that the statute of limitations had run on White’s fourth-offense

DUI charge. We find no error with the prosecution for aggravated DUI based on statute of

limitations or double jeopardy grounds. Finally, White showed no prejudice as a result of the

alleged prosecutorial misconduct. Accordingly, we affirm the judgment of conviction in part,

reverse and render in part, and remand for consideration of resentencing.

FACTS AND PROCEDURAL BACKGROUND

¶3. On November 1, 2021, White was driving on Highway 18 in Hinds County when she

failed to yield to another driver’s right of way and crashed into a vehicle carrying four

members of the Conaway family: Allison, the driver and mother of the passengers; Alex, who

was six months old; Chelsey, who was four years old; and Chloe, who was seven years old.

Allison was pronounced dead at the scene, and Alex later died from his injuries. Chelsey and

Chloe survived but sustained traumatic brain and neck injuries that could cause future

complications with their physical, emotional, and mental abilities.

¶4. Multiple witnesses testified at trial that White was driving erratically and dangerously

in the moments before the fatal crash. When law enforcement arrived at the scene, officers

noticed a strong odor of alcohol coming from White. White refused field sobriety testing, so

an officer obtained a warrant for a blood draw, which revealed that White’s blood-alcohol

concentration (BAC) was 0.273% near the time of the crash. White’s blood test also revealed

that White had consumed hydrocodone, amitriptyline, and marijuana.

¶5. On March 25, 2022, a Hinds County grand jury indicted White on four counts of

aggravated DUI. Each count alleged that White had been “operating a motor vehicle in

2 violation of Section 63-11-30(1)(d)(i) . . . while having a [BAC] of 0.273%.” White

proceeded to trial in November 2023; but the jury was unable to reach a verdict, and the

circuit court declared a mistrial.

¶6. On December 8, 2023, a Hinds County grand jury returned a second indictment

against White. The December 2023 indictment included four counts of aggravated DUI but

this time alleged different subsections of the offense. Each count alleged that White drove

her vehicle

while under the influence of intoxicating liquor, and/or while having [a BAC of .08% or more], and/or was under the influence of any other substance that has impaired her ability to operate a motor vehicle, and/or was under the influence of any other substance that has impaired her ability to operate a motor vehicle, and/or was under the influence of any drug or controlled substance, the possession of which is unlawful under the Mississippi Controlled Substances law.

The December 2023 indictment also included a fifth count for fourth-offense DUI, which

alleged that White had three or more previous DUI convictions.

¶7. Before trial began on the December 2023 indictment, the State moved to nolle

prosequi1 the March 2022 indictment and proceed only on the December 2023 indictment.

The State’s motion was granted. White then filed a motion to dismiss the December 2023

indictment, arguing the crimes alleged in the December 2023 indictment were subject to a

two-year statute of limitations, which had expired on November 1, 2023. The circuit court

denied White’s motion, and the case proceeded to trial. A jury found White guilty of all five

counts. The circuit court sentenced White to twenty-five years for each count of aggravated

1 Nolle Prosequi, “To abandon (a suit or prosecution); to have (a case) dismissed by a nolle prosequi.” Black’s Law Dictionary (12th ed. 2024).

3 DUI and ten years for the count of fourth-offense DUI, each sentence to be served

consecutively.

ANALYSIS

¶8. White raises three issues on appeal. First, White argues the December 2023 indictment

must be dismissed because it was returned beyond the two-year statute of limitations. Second,

White claims even if the indictment was timely, the second prosecution is barred by double

jeopardy because it stems from the same facts and circumstances as her first trial. Third,

White argues the State committed prosecutorial misconduct when it mentioned plea

negotiations to the circuit court during a hearing on White’s motion to dismiss.

¶9. We affirm White’s convictions of the four counts of aggravated DUI, but we reverse

and render her conviction and sentence for fourth-offense DUI.

I. Statute of Limitations Barring Prosecution

¶10. We employ a de novo standard of review when considering the application of a statute

of limitations because it raises a question of law. Harper v. State, 404 So. 3d 1275, 1278 (¶8)

(Miss. Ct. App. 2025).

¶11. Mississippi Code Annotated section 99-1-5 (Rev. 2020) provides the limitations

period for criminal offenses and lists several specifically enumerated offenses with unlimited

limitations or specific limitations periods. However, section 99-1-5(2) also provides, “A

person shall not be prosecuted for any other offense not listed in this section unless the

prosecution for the offense is commenced within two (2) years after the commission thereof.”

Mississippi Code Annotated section 99-1-7 (Rev. 2020) provides that “prosecution may be

4 commenced . . . by the issuance of a warrant, or by binding over or recognizing the offender

to compel his appearance to answer the offense, as well as by indictment or affidavit.”

¶12. The December 2023 indictment charged White with aggravated DUI and fourth-

offense DUI, which were not specifically enumerated in the limitations statute. See id. § 99-

1-5. A prosecution for those offenses must begin within two years of the commission of the

offense. Id.

¶13. White argues the statute of limitations had run for all five charges by the time of the

December 2023 indictment because more than two years had passed since the events giving

rise to the indictment. White argues the nolle prosequi of the original, timely indictment

doomed the State’s prosecution because it brought the prosecution to an end. However, there

are two problems with White’s argument. One, we have concluded that prosecutions end only

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Beth Ann White v. State of Mississippi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/beth-ann-white-v-state-of-mississippi-missctapp-2026.