Yeatman v. Mississippi
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Jeffrey Yeatman pled guilty to one count of simple assault on a law-enforcement officer and two counts of third-offense driving under the influence. Each of the three counts had a separate cause number. The Circuit Court sentenced him: for simple assault on a law-enforcement officer (cause number 2006-0161-CR), five years imprisonment and a fine of $5,000 as a habitual offender; for third-offense DUI (cause number 2006-0327-CR), five years imprisonment and a fine of $5,000 as a habitual offender; and for third-offense DUI (cause number 2006-0328-CR), one year imprisonment, four years of post-release supervision, and a fine of $100. All sentences were to run consecutively. Yeatman sought post-conviction relief from his convictions for simple assault on a law-enforcement officer and third-offense DUI. The trial court denied post-conviction relief, and the Court of Appeals affirmed. The Supreme Court granted Yeatman's petition for a writ of certiorari. Because, by statute, the fine for simple assault on a law-enforcement officer was a maximum of $1,000, the Supreme Court vacated the $5,000 fine imposed on Yeatman for that crime, and remanded that case to the trial court for a determination of whether the criminal information in cause number 2006-0327-CR charged Yeatman as a habitual offender. The Supreme Court affirmed the trial court in all other respects.
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