Martin v. Mississippi
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Eugene Martin was convicted of shooting into a dwelling and sentenced as a habitual offender under Section 99-19-81. He claimed one of his two prior qualifying felony convictions resulted in a sentence of less than one year. Section 99-19-81 authorizes the State to seek increased punishment for those charged with a felony offense after having twice been convicted of prior felonies. But for this statutory enhancement to apply, the State must prove each of the defendant’s prior felony convictions resulted in a sentence of one or more years in a state or federal prison. If the State sought enhanced sentencing, and the requirements were met, Section 99-19-81 mandated the court sentence the defendant to the maximum term of imprisonment for the subject offense - in this case ten years. Martin argued he was wrongfully subjected to the sentencing enhancement. After review, the Supreme Court agreed, affirmed Martin’s conviction for
shooting into a dwelling, but reversed and remanded for resentencing.
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