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Bailey v. State

Citation: 270 So. 3d 108Docket: NO. 2017-CP-00757-COA

Court: Court of Appeals of Mississippi; August 7, 2018; Mississippi; State Appellate Court

Narrative Opinion Summary

The case involves an appeal by an individual sentenced in 2007 to fifteen years for armed robbery, seeking reconsideration and parole eligibility. After serving nearly eight years, the appellant filed a motion for reconsideration based on good behavior and educational achievements. The circuit court interpreted this as a motion for post-conviction relief but declared it time-barred and outside its jurisdiction, as the sentencing term had expired. On appeal, the appellant argued for parole eligibility under Mississippi Code Annotated section 47-7-3(1)(c)(i), a claim not previously raised in the lower court, rendering it inadmissible on appeal. Furthermore, the statute applied only to convictions between 1977 and 1994, making the appellant ineligible. The appeal court affirmed the lower court's judgment, emphasizing the procedural missteps and statutory inapplicability. The decision was unanimous among the justices.

Legal Issues Addressed

Applicability of Parole Eligibility Statute

Application: Bailey's conviction in 2007 renders him ineligible for parole under the statute he cited, which only applies to convictions between 1977 and 1994.

Reasoning: Even if considered, Bailey would be ineligible for parole since his conviction occurred in 2007, while the cited section only applies to convictions from 1977 to 1994.

Issue Raised for the First Time on Appeal

Application: Bailey's argument regarding parole eligibility was not raised in the circuit court and thus was barred from being considered on appeal.

Reasoning: However, this issue was not raised in the circuit court, rendering it barred on appeal.

Jurisdiction for Sentence Reduction

Application: The power to reduce a sentence after the sentencing term resides with the legislature, not the judiciary, as established in previous case law.

Reasoning: The court referenced previous cases establishing that a sentence reduction must occur before the expiration of the sentencing term, with the power to reduce sentences after the term residing with the legislature.

Post-Conviction Relief Time Bar

Application: The circuit court determined that the motion for reconsideration was time-barred as it was filed after the sentencing term had expired, lacking jurisdiction to reduce the sentence.

Reasoning: The circuit court treated this motion as one for post-conviction relief but deemed it time-barred and lacking jurisdiction to reduce the sentence, as the sentencing term had expired.