Hodges v. State

Summary

The Supreme Court of Mississippi reviews Quintez Wren Hodges's petition for post-conviction relief from his capital-murder conviction and death sentence. The court addresses procedural bars, including res judicata, and considers claims involving prosecutorial misconduct, admission of other-offense evidence, ineffective assistance of counsel, sentencing, jury instructions, and the death penalty. The opinion concludes that claims previously decided on direct appeal are generally barred, while certain ineffective-assistance claims supported by materials unavailable on direct appeal may be considered.

Holdings

1. Issues, both factual and legal, that were decided at trial or on direct appeal are barred from review as res judicata in post-conviction proceedings.
2. When an ineffective-assistance claim was raised on direct appeal but is supported in post-conviction proceedings by extraneous materials unavailable on direct appeal, res judicata does not bar consideration of the claim; however, merely rephrased claims remain barred.
3. Hodges failed to establish ineffective assistance of counsel because the remaining allegations did not satisfy both the deficient-performance and prejudice prongs of Strickland.

Questions Presented

1. Whether claims of prosecutorial misconduct, evidentiary error, sentencing error, indictment defects, jury-selection error, instructional error, and cumulative error that were decided on direct appeal were barred by res judicata in post-conviction proceedings.
2. Whether Hodges's ineffective-assistance-of-counsel claims were barred when they repeated claims raised on direct appeal, and whether claims supported by materials outside the direct-appeal record could be considered.
3. Whether the remaining ineffective-assistance-of-counsel allegations established deficient performance and prejudice under Strickland.
4. Whether the petition for post-conviction relief should be granted.

Disposition

denied