James J. Brumfield a/k/a James Brumfield v. State of Mississippi

CourtCourt of Appeals of Mississippi
DecidedJune 21, 2022
Docket2020-CP-01271-COA
StatusPublished

This text of James J. Brumfield a/k/a James Brumfield v. State of Mississippi (James J. Brumfield a/k/a James Brumfield 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
James J. Brumfield a/k/a James Brumfield v. State of Mississippi, (Mich. Ct. App. 2022).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2020-CP-01271-COA

JAMES J. BRUMFIELD A/K/A JAMES APPELLANT BRUMFIELD

v.

STATE OF MISSISSIPPI APPELLEE

DATE OF JUDGMENT: 10/23/2020 TRIAL JUDGE: HON. MICHAEL M. TAYLOR COURT FROM WHICH APPEALED: WALTHALL COUNTY CIRCUIT COURT ATTORNEY FOR APPELLANT: JAMES J. BRUMFIELD (PRO SE) ATTORNEY FOR APPELLEE: OFFICE OF THE ATTORNEY GENERAL BY: SCOTT STUART NATURE OF THE CASE: CIVIL - POST-CONVICTION RELIEF DISPOSITION: AFFIRMED - 06/21/2022 MOTION FOR REHEARING FILED: MANDATE ISSUED:

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

CARLTON, P.J., FOR THE COURT:

¶1. James Brumfield appeals the Walthall County Circuit Court’s denial of his motion for

post-conviction relief (PCR). In his PCR motion, Brumfield challenged the timeliness of his

probation revocation hearing. Finding no error, we affirm the circuit court’s order.

FACTS

¶2. In 2017, Brumfield was convicted in Walthall County of fleeing from a law

enforcement officer and possession of stolen property. The record indicates that Brumfield’s

sentence included a term of probation. On July 3, 2019, while released on probation,

Brumfield was arrested by the Marion County Sheriff’s Office on a separate indictment or by a charging affidavit for aggravated assault and attempted murder. According to

Brumfield, he “has been in continued custody since the date of his arrest on July 3, 2019.”

¶3. On January 22, 2020, Brumfield filed a PCR motion in the Walthall County Circuit

Court.1 In his motion, Brumfield claimed that shortly after he was arrested by the Marion

County Sheriff’s Office, he was served with a revocation warrant charging him with violating

the terms of his probation in Walthall County. Brumfield claimed that he has been held in

custody since July 3, 2019, without a preliminary hearing and without a probation revocation

hearing, in violation of Mississippi Code Annotated section 47-7-37(3) (Supp. 2018).

Brumfield argued that because the Mississippi Department of Corrections failed to hold a

preliminary hearing or a probation revocation hearing within the time frame provided by

section 47-7-37(3), he must “be released from custody and returned to probation status.”

Miss. Code Ann. § 47-7-37(3).

¶4. On October 23, 2020, the circuit judge entered an order denying Brumfield’s PCR

motion. Brumfield now appeals.

STANDARD OF REVIEW

¶5. We review a circuit court’s denial or dismissal of a PCR motion for an abuse of

discretion. Purvis v. State, 240 So. 3d 468, 470 (¶7) (Miss. Ct. App. 2017). A circuit court’s

denial or dismissal of a PCR motion will only be disturbed if the court’s findings are clearly

1 After filing his motion, Brumfield also filed additional motions and letters, all of which the circuit judge considered to be part of his PCR motion.

2 erroneous. Id. Questions of law are reviewed de novo. Id.

DISCUSSION

¶6. On appeal, Brumfield argues that he is being unlawfully detained while awaiting a

hearing on the violations of the conditions of his probation. Brumfield asserts that because

he has not received a probation revocation hearing within the time frame provided by section

47-7-37, he must be released from custody and returned to his prior probation status.

¶7. Section 47-7-37(3) provides as follows:

Whenever an offender is arrested on a warrant for an alleged violation of probation as herein provided, the department shall hold an informal preliminary hearing within seventy-two (72) hours of the arrest to determine whether there is reasonable cause to believe the person has violated a condition of probation. A preliminary hearing shall not be required when the offender is not under arrest on a warrant or the offender signed a waiver of a preliminary hearing. The preliminary hearing may be conducted electronically. If reasonable cause is found, the offender may be confined no more than twenty-one (21) days from the admission to detention until a revocation hearing is held. If the revocation hearing is not held within twenty-one (21) days, the probationer shall be released from custody and returned to probation status.

¶8. In its order denying Brumfield’s PCR motion, the circuit court found that Brumfield’s

PCR arguments were based on “a number of misunderstandings.” The circuit court

explained that while Brumfield was on probation, he was arrested by the Marion County

Sheriff’s Office for aggravated assault and attempted murder. Shortly after Brumfield’s

arrest in Marion County, the Walthall County Circuit Court issued a separate warrant for his

arrest due to material violations of the conditions of his probation, including absconding

supervision for a year, failing to pay supervision fees and court-imposed fines, and being

3 arrested for aggravated assault and attempted murder in Marion County. The circuit court

explained that Brumfield’s arrest by the Marion County Sheriff’s Office was the result of an

“indictment for new charges,” and not the result of Brumfield’s probation violations and a

later-issued warrant in Walthall County. The circuit court also stated that Brumfield’s

probation violations are material, rather than technical, in nature, “which alters the

application time limitations for revocation hearings.” The circuit court held that because

Brumfield was currently in custody “awaiting trial on his new charges” in Marion County,

the circuit court was allowed “reasonable time” to hold Brumfield’s revocation hearing.

¶9. The record before us does not contain the following documents: Brumfield’s 2017

sentencing order; the State’s motion to revoke Brumfield’s probation; or any order revoking

Brumfield’s probation.2 In his designation of the record on appeal, Brumfield requested to

include documents pertaining to his 2017 convictions. The only document he requested that

pertained to his present PCR motion was the circuit court’s order denying his PCR motion.

“The burden rests upon the appellant to see to it that the record contains all data essential to

an understanding and presentation of matters relied upon for reversal on appeal.” Brown v.

State, 54 So. 3d 882, 884 (¶10) (Miss. Ct. App. 2011) (quoting Shelton v. Kindred, 279 So.

2 Brumfield attached several documents to his initial appellate brief and reply briefs that are not a part of the record. “[T]his Court may not act upon or consider matters which do not appear in the record and must confine itself to what actually does appear in the record.” Brown v. State, 54 So. 3d 882, 884 (¶10) (Miss. Ct. App. 2011). The documents that Brumfield attached to his briefs are not part of the appellate record; therefore they will not be considered by this Court.

4 2d 642, 644 (Miss. 1973)). “Our law presumes that the judgment of the trial court is correct,

and the appellant has the burden of demonstrating some reversible error to this Court.” Sago

v. State, 978 So. 2d 1285, 1287 (¶3) (Miss. Ct. App. 2008).

¶10. The record shows that Brumfield was arrested on July 3, 2019, for attempted murder

and aggravated assault. The record also shows that at the time Brumfield filed his PCR

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Sago v. State
978 So. 2d 1285 (Court of Appeals of Mississippi, 2008)
Hill v. State
940 So. 2d 972 (Court of Appeals of Mississippi, 2006)
Brown v. State
54 So. 3d 882 (Court of Appeals of Mississippi, 2011)
Joseph Paul Purvis v. State of Mississippi
240 So. 3d 468 (Court of Appeals of Mississippi, 2017)
Armond Rakeem Lewis v. State of Mississippi
270 So. 3d 169 (Court of Appeals of Mississippi, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
James J. Brumfield a/k/a James Brumfield v. State of Mississippi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-j-brumfield-aka-james-brumfield-v-state-of-mississippi-missctapp-2022.