James Christopher Skinner v. State of Mississippi

Citation: 270 So. 3d 1046Docket: 2017-CA-01185-COA

Court: Court of Appeals of Mississippi; October 2, 2018; Mississippi; State Appellate Court

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James Christopher Skinner, also known as Christopher Skinner, appealed the Rankin County Circuit Court's dismissal of his postconviction relief (PCR) motion following his March 2011 convictions for disorderly conduct and felony evasion. The circuit court had sentenced Skinner as a habitual offender to six months in jail for disorderly conduct and life in prison without parole for felony evasion. The Court of Appeals of Mississippi found errors in the circuit court's dismissal, specifically: 1) the dismissal occurred after the Mississippi Supreme Court granted Skinner leave to file in the circuit court; 2) the circuit court incorrectly ruled that Skinner's PCR claim was barred by res judicata; and 3) the circuit court failed to consider mitigating factors from Skinner's childhood convictions when imposing his life sentence. The Court of Appeals reversed the dismissal and remanded the case for further proceedings. Prior to his trial, Skinner's indictment was amended to reflect his habitual offender status based on multiple prior convictions, including possession of a controlled substance and attempted carjacking with a firearm, for which he had served significant time in penal institutions.

On March 29, 2011, at a sentencing hearing, the State presented evidence of Skinner's habitual offender status, citing his 1994 Florida convictions for four nonviolent crimes, including carrying a concealed firearm and grand theft auto, which contributed to his ninth felony conviction for felony evasion. The defense contended that Skinner was only 15 years old at the time of the Florida offenses and urged the court to consider mitigating factors, particularly his mental health issues, including bipolar disorder and ADHD, which he was not medicated for during the relevant events. Dr. William Criss Lott, a clinical psychologist, testified that Skinner was competent to stand trial but noted that his mental health conditions could impair judgment and compliance with the law. Skinner’s mother corroborated that he was off his medications at the time of the crimes. The circuit court found that the State proved Skinner's status as a violent habitual offender and sentenced him to six months in county jail for disorderly conduct and life imprisonment without parole for felony evasion, with sentences running concurrently. At 32 years old during sentencing, Skinner later filed a motion for a judgment notwithstanding the verdict or a new trial, arguing that his prior convictions from age 15 should not qualify him as a habitual offender. The circuit court denied this posttrial motion after a hearing.

Skinner appealed his conviction and life sentence without eligibility for parole, claiming it constituted cruel and unusual punishment. The court affirmed the sentence, citing compliance with the habitual-offender statute, section 99-19-83, which has been upheld in previous cases as not violating the Eighth Amendment. The circuit court had amended Skinner’s indictment to reflect his prior convictions, including possession of a controlled substance and armed offenses. Given the severity of both his current and prior crimes, the court determined that no proportionality analysis was required, concluding there was no gross disproportionality in the sentence. 

Subsequently, Skinner sought permission from the supreme court to file a post-conviction relief (PCR) motion, which was granted. In his PCR motion, he argued the court should have considered mitigating circumstances from his juvenile convictions, asserting that he was only fifteen when those offenses occurred. The state did not respond to his motion. On August 1, 2017, the circuit court dismissed Skinner’s PCR motion, stating that the precedent set in Miller v. Alabama did not apply since Skinner was over thirty at the time of the current crime. The court noted that Miller only pertains to mandatory life sentences for crimes committed before the age of eighteen, and rejected Skinner's argument regarding his prior convictions influencing his current sentence.

Skinner's appeal continues, with the standard of review indicating that factual findings by the circuit court will only be overturned if clearly erroneous, while legal conclusions are reviewed de novo.

Skinner contends that the circuit court lacked the authority to summarily deny and dismiss his motion under Mississippi Code Annotated section 99-39-11(2) since the Mississippi Supreme Court had granted him leave to proceed with his post-conviction relief (PCR) motion. He argues that this grant necessitated further proceedings in the circuit court, which the court failed to undertake. The State counters that the circuit court did conduct further proceedings, citing Mitchell v. State, where the Supreme Court clarified that actions taken by the circuit court must adhere to the relevant sections following a grant by the Supreme Court. In Skinner's case, the circuit court found his claim barred by res judicata under section 99-39-21, which is recognized as a valid basis for further proceedings.

Additionally, the State references Porter v. State, which established that a grant of leave does not automatically entitle a petitioner to an evidentiary hearing. Instead, the circuit court may summarily deny a PCR motion if, after considering the filed answer and completed discovery, it finds that an evidentiary hearing is not warranted. The court emphasized that the Supreme Court's grant of leave only indicates a prima facie case, and the circuit court should assess whether an evidentiary hearing is necessary based on the specifics of the case rather than automatically proceeding to a hearing.

The circuit court failed to adhere to the procedural requirements outlined in Porter and section 99-39-19 when handling Skinner's post-conviction relief (PCR) motion. Specifically, the court did not request a response from the State prior to dismissing the motion, nor did it examine the record to decide if an evidentiary hearing was necessary. The supreme court's prior order had established a prima facie case, necessitating a response from the State. Given these procedural missteps, the dismissal of Skinner's PCR motion was reversed, and the case was remanded for further proceedings in accordance with the proper procedures. The court chose not to address additional issues raised by Skinner on appeal. The final decision was to reverse and remand the case.