Martin v. State
Docket Number: | 2002-KA-00400-SCT | |
Supreme Court: | Opinion Link Opinion Date: 04-22-2004 Opinion Author: Carlson, J. Holding: Affirmed |
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Additional Case Information: |
Topic: Murder - Competent to stand trial - Suppression of statements - Section 47-5-139 Judge(s) Concurring: Smith, C.J., Waller and Cobb, P.JJ., Easley, Graves and Dickinson, JJ. Non Participating Judge(s): Diaz, J. Procedural History: Jury Trial Nature of the Case: CRIMINAL - FELONY |
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Trial Court: |
Date of Trial Judgment: 08-01-2001 Appealed from: Jackson County Circuit Court Judge: James W. Backstrom Disposition: Convicted of murder and sentenced to life imprisonment. District Attorney: Keith Miller Case Number: 99-10,220(1) |
Party Name: | Attorney Name: | |||
Appellant: | Sam Ivan Martin |
ROSS PARKER SIMONS |
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Appellee: | State of Mississippi | OFFICE OF THE ATTORNEY GENERAL BY: DEIRDRE McCRORY |
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Synopsis provided by: If you are interested in subscribing to the weekly synopses of all Mississippi Supreme Court and Court of Appeals hand downs please contact Tammy Upton in the MLI Press office. |
Topic: | Murder - Competent to stand trial - Suppression of statements - Section 47-5-139 |
Summary of the Facts: | Sam Martin was convicted of murder and was sentenced to life imprisonment. He appeals. |
Summary of Opinion Analysis: | Issue 1: Competent to stand trial Martin argues that the court erred in finding him competent to stand trial. The standard for competence to stand trial is whether the defendant has sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding and has a rational as well as factual understanding of the proceedings against him. Although there was a conflict in the testimony of the two psychiatrists who examined Martin as to whether he was competent to stand trial, the conflict is properly resolved by the trier of fact and there was no error in the court’s determination that Martin was competent to stand trial. Issue 2: Suppression of statements Martin argues that the court erred in denying his motion to suppress two inculpatory statements he made to law enforcement, because he never knowingly, voluntarily or intelligently waived his rights to an attorney and the statements were elicited by undue coercion. For a confession to be admissible, it must have been given voluntarily and not as a result of promises, threats or inducements. A confession will not ordinarily be excluded merely because the person making the confession is mentally weak unless the person has been overreached to the end that he has divulged that which he would not have divulged had he not been overreached. Based on the testimony in this case, the court's finding regarding Martin's ability to voluntarily, knowingly and intelligently waive his rights and make two separate statements was not clearly erroneous or against the overwhelming weight of the evidence. Issue 3: Section 47-5-139 Martin argues that the statute which governs when a party can be conditionally released from a life sentence, section 47-5-139, violates his due process rights and equal protection rights because the statute makes an age-based distinction which lengthens a criminal sentence due to the age of an inmate. Not only is the proper place for application of this statute in a petition for post-conviction relief, but section 47-5-139 is not violative of Martin’s due process and equal protection rights by specifying criteria to consider in determining which inmates may or may not be considered for earned time allowance. |
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