OF JUDGMENT: 05/31/2016
FROM WHICH APPEALED SMITH COUNTY CIRCUIT COURT HON. STANLEY
ALEX SOREY TRIAL JUDGE
ATTORNEY FOR APPELLANT: JASON CAISSIE (PRO SE)
ATTORNEY FOR APPELLEE: DAVID GARNER
GRIFFIS, P.J., WESTBROOKS AND TINDELL, JJ.
The Raleigh Municipal Court found Jason Caissie guilty of
operating a motor vehicle without a valid driver's
license and failing to maintain or provide proof of
insurance. See Miss. Code Ann. §§ 63-1-5
& -7 & 63-15-4 (Rev. 2013). Caissie unsuccessfully
appealed his two misdemeanor convictions to Smith County
Circuit Court. On appeal from the circuit court's
judgment affirming his convictions, Caissie raises numerous
issues, which we restate as follows: (1) whether numerous
due-process violations rendered the municipal court's
judgment void; (2) whether the circuit court erred by
allowing an appeal from a void judgment; (3) whether the
circuit court erred by allowing his prosecution based on
"an illegal roadblock and false arrest"; (4)
whether the circuit court erred by failing to grant him
discovery; (5) whether the circuit court erred by quashing
the subpoenas he issued to the Commissioners of the
Mississippi Department of Revenue and the Mississippi
Department of Public Safety; (6) whether the circuit court
erred by failing to accept his plea of "non assumpsit by
way of confession and avoidance"; (7) whether error
occurred because the prosecution failed to provide the
statutory law he was charged with violating; (8) whether
error occurred because the prosecution failed to provide him
with a charging instrument; (9) whether the circuit court
erred by denying his request to voir dire his court-appointed
armchair counsel; (10) whether the circuit court erred by
refusing his request for "next friend" counsel;
(11) whether error occurred because the prosecution failed to
answer or address several of his pretrial filings; and (12)
whether the circuit court erred by excluding an audio
recording he attempted to admit into evidence.
Finding no error in the circuit court's judgment, we
While driving through the town of Raleigh, Mississippi (the
Town), on April 25, 2015, Caissie encountered a safety
checkpoint conducted by Officer Ricky Hand of the Raleigh
Police Department. Officer Hand asked Caissie to produce a
valid driver's license and proof of insurance. When
Caissie failed to comply with the request, Officer Hand
arrested Caissie and issued him one ticket for operating a
motor vehicle without a valid driver's license and a
separate ticket for failing to maintain or provide proof of
The municipal court found Caissie guilty of both offenses.
Caissie then appealed to the circuit court, which tried the
charges de novo. Following a bench trial on May 12, 2016, the
circuit court found Caissie guilty of both charges and
ordered him to pay a $500 fine for each offense, for a total
fine of $1, 000. Caissie filed an unsuccessful new-trial
motion. Aggrieved by the circuit court's judgment,
Caissie now appeals his misdemeanor convictions to this
Court. As needed, we will relate any additional facts during
our discussion of the issues Caissie raises on appeal.
The appellate courts affirm a trial judge's decision in a
bench trial where substantial, credible, and reasonable
evidence supports the decision. Parish v. State, 176
So.3d 781, 785 (¶13) (Miss. 2015). We only reverse the
findings of a trial judge sitting without a jury when the
trial judge was clearly wrong or committed manifest error.
Harvey v. State, 195 So.3d 231, 232 (¶5) (Miss.
Ct. App. 2016).
Whether numerous due-process violations rendered the
municipal court's judgment void.
Whether the circuit court erred by allowing an appeal from a
Caissie first contends that numerous due-process violations
occurred prior to and during his municipal-court trial and
rendered the municipal court's judgment
void. Related to this argument, Caissie asserts
that the circuit court committed reversible error by allowing
a void judgment to form the basis of an appeal.
Uniform Rule of Circuit and County Court 5.01 establishes
that a direct appeal from justice or municipal court to
circuit court "shall be by trial de
novo." This remains true even where the appellant
pled guilty in justice or municipal court. Jones v.
State, 972 So.2d 579, 580 (¶3) (Miss. 2008). Even
if defects exist in the justice or municipal court's
judgment, such defects amount to harmless error when a
defendant appeals and receives a trial de novo. Stidham
v. State, 750 So.2d 1238, 1245 (¶31) (Miss. 1999);
see also Hitt v. State, 149 Miss. 718, 718, 115 So.
879, 883 (1928) (recognizing that a de novo trial in circuit
court "was as if there had never been a trial before a
justice of the peace, and was effectual to correct
any and all errors committed by the justice of the
peace either as to a ruling of law, or as to a
ruling on facts" (emphasis added)). Because
Caissie appealed his misdemeanor convictions and received a
de novo trial in circuit court, we find no merit to his
claims regarding the alleged defects in and the validity of
the municipal court's judgment against him.
III.Whether the circuit court erred by allowing
Caissie's prosecutionbased on "an