Background
At age 14, Carly Madison Gregg shot and killed her mother, Ashley Smylie, in March 2024. Afterward, Gregg used her mother’s phone to text her stepfather, hid a kitchen security camera, contacted friends, and told one friend that she had shot her mother and had ammunition for her stepfather. When her stepfather arrived home, Gregg shot him in the shoulder before he took the revolver from her.
A Rankin County jury convicted Gregg of first degree murder, attempted murder, and tampering with physical evidence. Her principal defense was insanity. A defense psychiatrist opined that a psychiatric crisis and dissociation left her unable to understand the nature or wrongfulness of her acts, while the State’s forensic psychiatrist relied on her planning, concealment, and statements after the shooting to conclude that she understood her conduct was wrong.
The Court’s Holding
The Mississippi Supreme Court affirmed all convictions and sentences. It held that the trial court’s blanket statement that it did not continue cases did not warrant reversal because Gregg never moved for a continuance or showed specific prejudice. The Court also held that the court prematurely ordered a sanity evaluation before formal notice of an insanity defense, but found the error harmless: Gregg did not meaningfully object, later gave notice and relied on insanity at trial, no sanity opinion resulted from the ordered evaluation, and she showed no resulting prejudice.
The Court concluded that the admission of a counselor’s detailed summary of Crime and Punishment should have been limited because it had little demonstrated connection to Gregg’s conduct and posed a risk of unfair prejudice. But the error was harmless in light of the evidence supporting the jury’s rejection of insanity. On sentencing, the Court held that the jury and court imposed “life imprisonment,” not life without parole. It found the sentences lawful, held that the sentencing proceeding complied with Miller v. Alabama, and rejected challenges to the prosecutor’s sentencing argument.
Key Takeaways
- A court should not use a blanket no-continuance policy, but reversal requires an actual adverse ruling and demonstrated prejudice.
- Rule 12.2(b) requires a defendant to timely raise insanity before a court orders an examination of sanity at the time of the offense.
- For a juvenile convicted of first degree murder after July 1, 2024, Mississippi Code Section 97-3-21(2)(b) authorizes life imprisonment but does not expressly authorize life without parole.
Why It Matters
The decision distinguishes juvenile “life imprisonment” from juvenile life without parole under Mississippi’s 2024 homicide-sentencing amendments. Although the sentencing instructions improperly suggested differing parole consequences, the Court treated the written jury verdict and sentencing order—both imposing life imprisonment—as controlling.
The opinion also underscores that procedural and evidentiary errors, including an improperly sequenced sanity evaluation and marginally relevant evidence, will not overturn a conviction absent a concrete showing that they affected the verdict.