Following an incident in Grenada Municipal Court described in a Mississippi Supreme Court decision as “wilful misconduct,” Judge Carlos E. Moore has been suspended without pay, ordered to pay a fine and will face a public reprimand.
The incident occurred on Dec. 8, 2020, according to the Supreme Court decision issued last Thursday, Feb. 16, 2023. It states that Judge Moore, who is a municipal judge for the cities of Grenada and Clarksdale, and also practices law with The Cochran Firm, “criticized” Grenada Police Department Chief George Douglas and Det. Sgt. Chris Brown “publicly” during open court concerning a discussion about a private client of Moore’s that occurred four days earlier at his private law office, located on Branscome Drive in Grenada.
The private client of Judge Moore’s was a victim of a shooting at the Satan’s Sidekick Clubhouse in Grenada in November 2020, according to the Mississippi Commission of Judicial Performance, which filed the formal complaint against Judge Moore. The complaint was filed “alleging that he improperly summoned two local police officers to the municipal courtroom in Grenada and criticized them publicly.”
According to the decision, the Commission and Judge Moore asked the Court to “accept the stipulated findings of fact” and to approve the recommended sanctions of a public reprimand and fine of $1,500. The Court disagreed.
“After careful consideration of the judicial misconduct at issue, we are unable to agree fully with the recommendation of the Commission,” the decision read. “Because Judge Moore abused the power of his office to chastise and embarrass police officers in open court concerning a matter related to the judge’s private law practice, we order a 60-day suspension from judicial office without pay in addition to the recommended sanctions.”
Chief Douglas was contacted Monday morning regarding last Thursday’s decision, but remained tight lipped.
“I have no comment,” he said, adding that Detective Sgt. Brown would also not be making a comment.
Judge Moore also declined to comment.
According to the decision, Judge Moore’s public reprimand “shall be read in open court by the presiding judge of the Grenada County Circuit Court on the first day of the next term of that court in which a jury venire is present” following the issuance of the Supreme Court’s mandate. The decision mandates that the public reprimand also be read as stated above in Coahoma County Circuit Court.
“Judge Moore shall stand within the well of the court, before the bench, and the circuit judge shall read, aloud and in the hearing of all in attendance, the following public reprimand, in its entirety:”
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Public Reprimand
The Mississippi Supreme Court recently decided the case of Mississippi Commission on Judicial Performance v. Carlos E. Moore. Carlos E. Moore is a municipal court judge for the Mississippi cities of Grenada and Clarksdale, and he also maintains a private law practice.
On December 4, 2020, Detective Sergeant Chris Brown of the Grenada Police Department, along with a Mississippi Bureau of Investigation officer and a district attorney’s investigator, interviewed a client of Moore’s at his private law office. During the interview, Attorney Moore learned that a search warrant had been issued for his client’s telephone records. A disagreement arose over the search warrant, and Attorney Moore told the officers to leave his office.
Four days later, Judge Moore, in his official capacity as a municipal court judge, held court in Grenada Municipal Court. He sent word to Grenada Police Chief George Douglas and Detective Sergeant Chris Brown to come to the courtroom. When they arrived, Judge Moore stopped the court proceedings that were in progress and had both officers stand before him at the bench. He denied Detective Sergeant Brown’s request for the discussion to take place in the judge’s chambers, then proceeded to chastise and embarrass the two officers publicly regarding the December 4 incident at Moore’s law office.
The Mississippi Supreme Court ruled that this conduct violated the Mississippi Code of Judicial Conduct and ordered sanctions against Judge Moore, including a 60-day suspension from judicial office in both Grenada and Clarksdale, without pay, a $1,500 fine, and a public reprimand, to be read in open court by the presiding judge of the Grenada County Circuit Court on the first day of the next term of that court in which a jury venire is present after the issuance of the Supreme Court’s mandate. Likewise, the public reprimand shall be read in open court by the presiding judge of the Coahoma County Circuit Court on the first day of the next term of that court in which a jury venire is present after the issuance of the Supreme Court’s mandate.
THEREFORE, by order of the Mississippi Supreme Court, Municipal Court Judge Carlos E. Moore is hereby publicly reprimanded for his violation of the following canons of the Mississippi Code of Judicial Conduct:
Canon 1 provides that “[a] judge should participate in establishing, maintaining, and enforcing high standards of conduct, and shall personally observe those standards so that the integrity and independence of the judiciary will be preserved.”
By using his judicial authority in a public courtroom to deal with a conflict that had arisen from his private law practice, Judge Moore failed to observe the high standard of conduct required to preserve the integrity and independence of the judiciary.
Canon 2 provides that “[a] judge shall . . . act at all times in a manner that promotes public confidence in the integrity and impartiality of the judiciary[,]” and that “Judges shall not lend the prestige of their offices to advance the private interests of the judges or others . . . .”
Judge Moore’s choice of a public courtroom, in which court was in session with him presiding, as a place to scold law enforcement officers for a matter concerning one of his private clients did nothing to promote public confidence in the integrity and impartiality of the judiciary and likely had an opposite effect. Judge Moore also violated Canon 2 by lending the prestige of his judicial office to advance the private interests of himself and his client. Additionally, the underlying conflict was related to an official investigation of a criminal matter, heightening the severity of the misconduct.
Canon 3 provides that “Judges shall be patient, dignified, and courteous to litigants, jurors, witnesses, lawyers, and others with whom they deal in their official capacities…”
Judge Moore’s public criticism of the officers he compelled to stand before the judge’s bench while he embarrassed them in the presence of everyone in the courtroom was devoid of the dignified decorum that judges are required to maintain, especially in court.
Canon 4 requires a judge to conduct his extrajudicial activities so they do not “(1) cast reasonable doubt on the judge’s capacity to act impartially as a judge; (2) demean the judicial office; or (3) interfere with the proper performance of judicial duties.”
Judge Moore created a conflict with his judicial obligations when he deliberately engineered a courtroom encounter with the two officers, during a session of court over which he was presiding, for the purpose of confronting them about a dispute related to his private law practice and unrelated to anything that was before the Grenada Municipal Court at that time. Using his judicial authority to create a captive audience composed of two law enforcement officers against whom the judge had an extrajudicial grievance was demeaning to the judicial office and cast doubt on Moore’s capacity to act impartially in his role as a judge.
This concludes the public reprimand of Municipal Court Judge Carlos E. Moore.
Formal Complaint
“According to the Commission’s formal complaint, a private client of Judge Moore’s was a victim of a shooting at the Satan’s Sidekick Clubhouse in Grenada in November 2020. On December 4, 2020, Detective Sergeant Chris Brown of the Grenada Police Department (along with a Mississippi Bureau of Investigation officer and a district attorney’s investigator) interviewed the client at Moore’s private law office. During the meeting, Moore learned that a search warrant had been issued for his client’s telephone records. A disagreement arose concerning the search warrant, with Moore telling the officers he would evaluate whether the warrant was valid before advising his client to comply with it. Moore terminated the interview and told the officers to leave his office. Detective Sergeant Brown said to Moore, “I’ve got your number,” which Moore interpreted as a threat. Moore called Brown’s superior, Police Chief George Douglas, to initiate a complaint; but when he was told that the complaint had to be in writing, he chose not to file one.
“Four days later, Judge Moore, in his official capacity as a municipal court judge, held court in Grenada Municipal Court, which is housed in the same building as the municipal police headquarters. Prior to the commencement of the day’s proceedings, Judge Moore sent word to Grenada Police Chief Douglas and Detective Sergeant Brown to come to the courtroom. When the officers entered the courtroom, Judge Moore halted the court proceedings and directed both men to stand before him at the bench. Despite Detective Sergeant Brown’s request that the discussion be held in the privacy of the judge’s chambers, Judge Moore proceeded, in the presence of the people in the courtroom, to chastise the officers regarding the meeting on December 4, 2020. According to the Commission’s complaint, Judge Moore accused Detective Sergeant Brown of threatening to cause bodily harm to Moore based on the remark he had made while leaving Moore’s law office. Additionally, the formal complaint alleged that Judge Moore labeled Detective Sergeant Brown a racist. The complaint said also that Moore had threatened to have Brown arrested if he ever visited one of Moore’s properties again.
“The Commission filed the formal complaint against Moore on May 12, 2021, citing violations of Section 177A of the Mississippi Constitution and Canons 1, 2A, 2B, 3B(3), 3B(4), and 4A of the Code of Judicial Conduct. Judge Moore responded, denying the complaint’s characterization of some of the events, including that the exchange at the law office was “heated” and the allegation that he had called Officer Brown a racist. On February 23, 2022, in lieu of a formal hearing, Judge Moore joined a Stipulation of Agreed Facts and Recommendation, which was unanimously approved by the Commission. Moore stipulated that on December 4, 2020, he had “kicked all three law enforcement officers out of his office” after “some discussion and disagreement about the search warrant” for his client’s telephone records. He further stipulated that he had asked the police chief and Detective Sergeant Brown to “appear in his courtroom,” that he had “halted the court proceedings and had both officers stand before him at the bench,” that he had denied the request to have the discussion take place in chambers, and that he had “publicly chastised and embarrassed the two officers in the presence of the entire courtroom.”
“On May 16, 2022, the Commission rendered its findings of fact and conclusions of law, recommending that Judge Moore be publicly reprimanded and fined $1,500. The Commission moved this Court to accept its recommendation on June 21, 2022. Judge Moore filed a response joining the Commission’s motion.”
The complete Mississippi Supreme Court decision, including violation descriptions, can be viewed in its entirety by clicking the link below:
Carlos Moore Supreme Court Decision
