Brown v. MississippiAnnotate this Case
A jury found Alvin Brown guilty of manslaughter and four counts of aggravated assault. The circuit court sentenced Brown to twenty years in the custody of the Mississippi Department of Corrections for manslaughter and ten years for each aggravated assault conviction, with the aggravated assault sentences to run concurrently with each other and consecutively to the manslaughter sentence. Brown appealed and the Court of Appeal reversed and remanded for a new trial as to only the aggravated assault convictions due to a variance between the indictment and the jury instructions. Finding no merit as to Brown's appeal of the self-defense instruction, the appellate court affirmed. Because the Court of Appeals’ affirmed the trial court’s decision to give the State’s imperfect self-defense instruction, which conflicted with controlling caselaw affirming the refusal of imperfect self-defense instructions when requested by defendants, the Supreme Court also reversed Brown’s manslaughter conviction.