Hawkins v. State of Mississippi
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In the case at hand, the Supreme Court of Mississippi dealt with an appeal by George Hawkins who was convicted for sexual battery of a minor under Mississippi Code Section 97-3-95(2). This law requires the State to prove that the defendant was in a position of trust or authority over the minor when the crime was committed. Hawkins' appeal was based on the argument that the State failed to present sufficient evidence of him being in such a position over the victim, as he had no legal authority over her.
In 2014, Hawkins began dating Tonya Ingram and gradually became a part of her and her children’s lives, to the point where they even considered themselves to be common-law married. In the spring of 2015, Tonya and her children moved into Hawkins's home "as a family". Hawkins and Tonya filed their taxes jointly, claimed Tonya’s children as dependents, and contributed equally to the family’s finances. The victim, Jane, one of Tonya's children, trusted Hawkins, which ended when he sexually assaulted her one night.
The court found that while Hawkins did not possess any legal authority over Jane, a reasonable jury could have concluded that he was in a position of trust or authority over her based on the totality of the circumstances and their relationship. The court held that the list of individuals who are typically in positions of authority provided in Section 97-3-95(2) serves only as examples, and does not limit this to persons in positions of legal authority over the child. Therefore, the court affirmed Hawkins' conviction.
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