Willie Nash a/k/a Willie Cole Nash v. State of Mississippi

CourtMississippi Supreme Court
DecidedApril 9, 2020
Docket2018-KA-01587-SCT
StatusPublished

This text of Willie Nash a/k/a Willie Cole Nash v. State of Mississippi (Willie Nash a/k/a Willie Cole Nash v. State of Mississippi) is published on Counsel Stack Legal Research, covering Mississippi Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Willie Nash a/k/a Willie Cole Nash v. State of Mississippi, (Mich. 2020).

Opinion

IN THE SUPREME COURT OF MISSISSIPPI

NO. 2018-KA-01587-SCT

WILLIE NASH a/k/a WILLIE COLE NASH

v.

STATE OF MISSISSIPPI

DATE OF JUDGMENT: 08/23/2018 TRIAL JUDGE: HON. MARK SHELDON DUNCAN TRIAL COURT ATTORNEYS: BRIAN KENNEDY BURNS BRITTANY WHITE BROWN MITCHELL DEE THOMAS COURT FROM WHICH APPEALED: NEWTON COUNTY CIRCUIT COURT ATTORNEY FOR APPELLANT: WILLIAM B. BARDWELL ATTORNEY FOR APPELLEE: OFFICE OF THE ATTORNEY GENERAL BY: MATTHEW WYATT WALTON DISTRICT ATTORNEY: STEVEN SIMEON KILGORE NATURE OF THE CASE: CRIMINAL - FELONY DISPOSITION: AFFIRMED - 01/09/2020 MOTION FOR REHEARING FILED: 01/23/2020; DENIED AND OPINION MODIFIED ON PAGE 1 AND AT ¶ 13 - 04/09/2020 MANDATE ISSUED:

BEFORE KING, P.J., MAXWELL AND GRIFFIS, JJ.

MAXWELL, JUSTICE, FOR THE COURT:

¶1. A jury found Willie Nash guilty of possession of a cell phone in a correctional facility.

Nash does not appeal the jury’s verdict. He only challenges his sentence, twelve years in

prison. He claims the twelve-year sentence is grossly disproportionate to the crime and thus

violates the Eighth Amendment. ¶2. Though harsh, Nash’s sentence falls within the statutory range of three to fifteen

years. And the judge based his sentencing decision on the seriousness of Nash’s crime and

evidence of Nash’s criminal history. Because Nash has not shown that a threshold

comparison of the crime committed to the sentence imposed leads to an inference of gross

disproportionality, no further analysis is mandated. We affirm Nash’s conviction and

sentence.

Background Facts and Procedural History

¶3. While confined at the Newton County Jail on a misdemeanor charge, Nash asked a

jailer for “some juice.” At first, the jailer thought Nash was asking for something to drink.

But then Nash slid across a cell phone that he had on his person. The jailer took the phone

and gave it to the sheriff’s deputy in charge. Nash later denied the phone was his. But when

the deputy sheriff unlocked the phone—using the code Nash had given the jailer—he found

photos of Nash, as well as a text-message exchange from the day Nash had handed over the

phone in jail. The incoming message asked, “WYA” (short for “where you at”), and the

outgoing message responded, “in jail.”

¶4. A jury convicted Nash of possessing a cell phone in a correctional facility in violation

of Mississippi Code Section 47-5-193 (Rev. 2015). Any person who violates Section 47-5-

193 “shall be guilty of a felony and upon conviction shall be punished by confinement in the

Penitentiary for not less than three (3) years nor more than fifteen (15) years . . . .”1 Miss.

Code Ann. § 47-5-195 (Rev. 2015). At Nash’s sentencing hearing, the trial judge informed

1 Nash’s conviction also carried a potential fine of up to $25,000. Miss. Code Ann. § 47-5-195. Nash was fined $5,000.

2 Nash that, while his crime may have seemed insignificant to him, there was a reason

possessing a cell phone in a correctional facility “is such a serious charge.” The judge also

told Nash to “consider yourself fortunate.” Based on Nash’s prior burglary convictions, he

could have been indicted as a habitual offender. This would have subjected him to a fifteen-

year sentence to be served day for day. Miss. Code Ann. § 99-19-81 (Supp. 2019). The trial

court sentenced Nash below the statutory maximum to a term of twelve years in the custody

of the Mississippi Department of Corrections.2

¶5. Nash filed a motion for new trial challenging the sufficiency of the State’s evidence

and the trial court’s evidentiary rulings. The trial court denied this motion, and Nash

appealed.

Discussion

¶6. On appeal, Nash challenges his sentence only. He argues his twelve-year sentence

violates the Eighth Amendment of the United States Constitution because it is grossly

disproportionate to his crime of possessing a cell phone in jail.

¶7. The State argues Nash failed to preserve his claim because he did not challenge his

sentence’s proportionality before the trial court either at sentencing or in his motion for a new

trial. Despite the State’s assertion,3 we address the merits of Nash’s sentence-

2 Nash will become parole eligible after serving a quarter of his sentence. Miss. Code Ann. § 47-7-3(1) (Supp. 2019). 3 As was the case in Portis v. State, 245 So. 3d 457, 474 n.15 (Miss. 2018), we have serious doubts concerning Nash’s reasonable opportunity to raise this issue at trial. It would have been difficult for Nash to have teed up the proportionality issue at his sentencing hearing without yet knowing where in the three-to-fifteen-year range his sentence would fall. And the new Mississippi Rules of Criminal Procedure do not provide a clear vehicle for a

3 based claim. As we recently noted, Eighth Amendment challenges assert an important

constitutional right, and this Court “will indulge in every reasonable presumption against the

waiver of a constitutional right.” Portis v. State, 245 So. 3d 457, 474 n.15 (Miss. 2018)

(quoting Brooks v. State, 903 So. 2d 691, 695 (Miss. 2005)); see also Edwards v. State, 800

So. 2d 454, 468-69 (Miss. 2001) (addressing the merits of the defendant’s sentence

proportionality, despite being “not bound” to consider statistical evidence that was not first

presented to the trial court).4

I. Severity of Crime

¶8. Nash begins his proportionality challenge by asking this Court to recognize “differing

degrees of transgression” under Section 47-5-193. Section 47-5-193 prohibits any offender

confined to a correctional facility from possessing “any weapon, deadly weapon,

unauthorized electronic device, contraband item, or cell phone or any of its components or

accessories to include, but not limited to, Subscriber Information Module (SIM) cards or

chargers.” Nash argues this statute creates “three categories . . . of a descending order in

post-trial challenge to a sentence only. Rule 25.1 permits a trial court to vacate a judgment and grant a new trial. MRCrP 25.1. But that is not what Nash is seeking with his proportionality claim. He does not ask to set aside his judgment of conviction and have a new trial. Rather, he seeks a new, lesser sentence. The same is true of a Rule 25.2 motion to vacate judgment. The rule permits a trial court to vacate a judgment “if the indictment or charging affidavit did not charge an offense, or if the trial court was without jurisdiction.” MRCrP 25.2(a). It does not permit a defendant to move to vacate a sentence only based on alleged constitutional deficiencies. 4 But see Horne v. State, 825 So. 2d 627, 641 (Miss. 2002) (refusing to engage in proportionality analysis for the first time on appeal, because life in prison was the only sentencing option, and the defendant “never asked the circuit court to perform a proportionality review”).

4 severity.” As Nash sees it, possession of weapons is the most serious offense, possession of

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Willie Nash a/k/a Willie Cole Nash v. State of Mississippi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/willie-nash-aka-willie-cole-nash-v-state-of-mississippi-miss-2020.