Justia Mississippi Supreme Court Opinion Summaries

A man was stopped by a police officer for a window tint violation while riding as a passenger in a vehicle driven by a family acquaintance. During the stop, the officer observed behavior from the man that suggested narcotics use. The officer searched a bag in the vehicle, which the man identified as his, and found what appeared to be crystal methamphetamine and a used methamphetamine pipe. The man was arrested at the scene, and the driver left. The man was subsequently indicted for possession of methamphetamine, and at trial, he testified that the drugs were not his and that he did not know the driver well, though she was a family friend.At trial in the Circuit Court of Madison County, the State presented evidence including the testimony of the arresting officer and a crime lab analyst. The defendant’s only witness was himself. In closing argument, the prosecutor highlighted that the defendant, who blamed the drugs on the driver, had not called her as a witness, even though she was known to him and accessible through family. The jury found the defendant guilty, and the trial court denied post-trial motions for a judgment notwithstanding the verdict or a new trial.On appeal to the Supreme Court of Mississippi, the defendant argued that the prosecutor’s comments in closing were improper because they referenced his failure to call the driver as a witness. The Supreme Court reviewed the claim for plain error, since no objection was made at trial. The Court held that there was no error because the witness was more available to the defendant than to the State, given her relationship to the defendant’s family. The conviction and sentence were affirmed. View "Hollingsworth v. State of Mississippi" on Justia Law

In December 2022, Mariah Karriem was attacked outside a hookah lounge in Lowndes County, Mississippi by three individuals, including Kierra Wallace, her sister, and her cousin. Karriem was punched, kicked, and struck several times with a glass bottle, sustaining minor injuries that required minimal medical treatment. The attack was recorded on video, and Karriem later identified her assailants as they fled the scene. A longer video of the incident and a Facebook Live recording of Wallace and her sister admitting to the assault were admitted into evidence.The case was tried before the Lowndes County Circuit Court, where the jury found Wallace guilty of aggravated assault. She was sentenced to twenty years in the custody of the Mississippi Department of Corrections, with five years suspended and five years of post-release supervision. Following sentencing, Wallace filed a motion for judgment notwithstanding the verdict or for a new trial, arguing, among other things, that newly discovered video evidence exculpated her. The trial court held a hearing and found the new video was cumulative of evidence already presented and not exculpatory, denying the motion.On appeal, the Supreme Court of Mississippi reviewed Wallace’s claims regarding a defective indictment, constructive amendment of the indictment, sufficiency of the evidence, and denial of the motion for a new trial. The Court held that the indictment was not defective, as it did not conflate intent elements and Wallace’s defense was not prejudiced. The Court found Wallace was estopped from challenging a jury instruction due to the invited-error doctrine. Reviewing the evidence de novo, the Court found it sufficient for a rational juror to convict. It also held the trial court did not abuse its discretion in denying a new trial. The conviction was affirmed. View "Wallace v. State of Mississippi" on Justia Law

An employee who suffered a workplace injury sued his employer’s workers’ compensation insurance carrier and related entities, alleging failure to authorize timely medical treatment and misrepresentation of his injuries to the Mississippi Workers’ Compensation Commission. The plaintiff filed the lawsuit in Hinds County, Mississippi, though the only resident defendant lived in Rankin County. The defendants, all nonresidents except one, removed the case to federal court, invoking diversity jurisdiction and asserting that the resident defendant was improperly joined. While in federal court, the defendants filed a motion to dismiss based on failure to exhaust administrative remedies but did not raise a venue objection.The United States District Court for the Southern District of Mississippi found that it lacked subject-matter jurisdiction because the defendants had not met their burden to show improper joinder and remanded the case to the Hinds County Circuit Court. After remand, and before filing an answer or conducting discovery, the defendants moved to transfer venue to Rankin County. The plaintiff argued that any venue objection was waived because it was not raised in federal court, and the Hinds County Circuit Court denied the motion to transfer based solely on waiver, relying on the Mississippi Supreme Court’s decision in Breal v. Downs Law Group.The Supreme Court of Mississippi held that the defendants did not waive their objection to venue by failing to raise it in federal court, as the issue of proper state-court venue was not available while the case was pending in federal court. The court distinguished the facts from those in Breal and clarified that the defense of improper venue was timely asserted at the first opportunity in state court. The Supreme Court of Mississippi reversed the trial court’s denial of the motion to transfer venue and remanded the matter for further proceedings. View "Benchmark Insurance Company v. Harris" on Justia Law

A dispute arose between two competing billboard companies after one company constructed an electronic billboard in Gulfport, Mississippi. The company that operated existing billboards nearby filed suit, claiming that the new billboard violated a city ordinance enacted as part of a settlement resolving earlier litigation involving the city and the plaintiff. The defendant, along with related entities, countered with claims for declaratory and injunctive relief and challenged the plaintiff’s standing to bring the suit. The property owner on whose land the disputed billboard was constructed also became a party to the litigation.The litigation began in the Chancery Court of Harrison County, which denied the defendants’ motion for summary judgment, specifically rejecting their standing argument. The defendants removed the case to federal court, which remanded it and awarded costs to the plaintiff. After the defendants’ interlocutory appeal was denied by the Supreme Court of Mississippi, the case was transferred to circuit court. There, the court again denied summary judgment, and further unsuccessful dispositive motions were filed by the defendants. Over several years, the case involved multiple motions, removal, transfer, and appeals, with no claims proceeding to trial. Eventually, after the defendants transferred their interest in the billboard to a third party who settled with the plaintiff, the plaintiff moved to dismiss the case with prejudice. The Circuit Court of Harrison County granted the motion and denied the defendants’ subsequent request for attorney’s fees and costs, finding that much of the litigation expense was due to the defendants’ own aggressive litigation strategies, and declined to impose sanctions, concluding the suit was not frivolous.The Supreme Court of Mississippi reviewed the appeal, focusing on whether the trial court erred in denying attorney’s fees and sanctions to the defendants. The court held that the decision to award attorney’s fees or impose sanctions was within the trial court’s discretion, and found no abuse of discretion in denying fees or sanctions, affirming the dismissal with prejudice. View "Busby v. The Lamar Company, LLC" on Justia Law

Four minor children were placed in the custody of the Mississippi Department of Child Protection Services (the Department) by the Warren County Youth Court in 2015. The children were subsequently placed in the care of their maternal aunt, Lesley Prince. In 2018, Prince and the children moved to Florida, where the Florida Department of Children and Families monitored them under the Interstate Compact on the Placement of Children. After parental rights were terminated in 2019 and adoption packages were issued in 2023, Prince sought to adopt the children but was unable to secure a court to adjudicate the petitions due to confusion over whether Mississippi or Florida had jurisdiction.Prince initially submitted adoption petitions to the Warren County Chancery Court, which declined to set a hearing, stating that Florida had jurisdiction since the children resided there. After efforts to find Florida counsel proved unsuccessful and receiving conflicting advice from the Florida authorities, Prince filed the petitions in Hinds County Chancery Court, which transferred the cases to Warren County. The Warren County Chancery Court again refused to set a hearing, maintaining it lacked jurisdiction. Prince then sought a permanency hearing in Warren County Youth Court to create a record for appeal. The Youth Court granted an interlocutory order, effectively ruling it lacked jurisdiction to adjudicate the adoptions.The Supreme Court of Mississippi reviewed the interlocutory appeal from the Warren County Youth Court. The Court held that exclusive jurisdiction over adoptions lies with the chancery courts under Mississippi law and statute, and not with youth courts. Therefore, it affirmed the Warren County Youth Court’s ruling that it lacked jurisdiction to finalize the adoptions. The Supreme Court did not address the merits of the adoption petitions or issue a directive to the chancery court, as only the jurisdictional question from the youth court’s order was properly before it. View "In The Matter of L.L.T." on Justia Law

Two financial advisors entered into two agreements as part of a business transaction: an operating agreement establishing them as members of a wealth management firm and a purchase-and-sale contract under which one advisor would gradually buy out the other's ownership interest. The operating agreement contained a noncompete clause and provisions for mediation and arbitration. After the buyout concluded, the selling advisor remained employed with the company and could only be terminated for cause. In January 2024, he was terminated for cause and immediately began working at a competing firm within the restricted radius specified in the noncompete provision.Following his termination, the company and the buying advisor filed suit in the Circuit Court of Forrest County, alleging breach of contract and seeking, among other relief, a temporary restraining order and preliminary injunction to enforce the noncompete clause. The trial court granted the injunction and denied the selling advisor’s motions to dissolve the restraining order, to deny the injunction, and to compel mediation and/or arbitration. The trial court found that the noncompete clause remained binding and that the parties had not shown a clear intent to compel mediation or arbitration for this dispute, given specific contractual language.On appeal, the Supreme Court of Mississippi reviewed whether the noncompete provision was enforceable, whether the trial court erred in issuing the preliminary injunction, and whether the denial of the motion to compel mediation/arbitration was proper. The Court held that the noncompete provision was binding based on the evidence at the preliminary injunction stage, that the trial court did not err in granting the preliminary injunction, and that the mediation/arbitration provisions were not clearly applicable to this dispute. The Supreme Court of Mississippi affirmed the trial court’s order in all respects. View "Wiggins v. Southern Securities Group, LLC" on Justia Law

A group of long-term care providers and their associated management company filed cost reports for 2015 with the Mississippi Division of Medicaid (DOM), reporting dividends received from three insurance companies as “other income” rather than offsetting them against insurance costs. This reporting practice had been consistently followed and accepted by DOM for over two decades. When DOM audited the 2015 cost reports around 2018, it changed its approach by offsetting these dividends against current insurance costs, thereby affecting reimbursement rates for services provided by the providers.After DOM made these adjustments, the providers sought reconsideration, but DOM upheld its decision. The providers then pursued an administrative appeal, where a hearing officer found DOM’s adjustments supported by substantial evidence and not arbitrary or capricious, recommending affirmation of DOM’s actions. DOM’s executive director adopted this recommendation. The providers appealed to the Hinds County Chancery Court, which affirmed DOM’s decision, concluding that the State Plan required reference to the Provider Reimbursement Manual (PRM) for guidance, and that DOM acted within its authority and did not violate any statutory or constitutional rights. The chancellor also found no evidence of a written internal policy regarding the treatment of such dividends.On appeal, the Supreme Court of Mississippi reviewed whether DOM’s actions were arbitrary and capricious, whether public notice of the change was required, and other issues. The Court held that DOM’s abrupt reversal of its long-standing unwritten internal policy, without reasonable explanation or public notice, was arbitrary and capricious. The Court further found that public notice was required under federal regulations for significant policy changes affecting payment rates. Accordingly, the Supreme Court of Mississippi reversed the decisions of DOM and the chancery court and rendered judgment in favor of the providers. View "Hattiesburg Medical Park Management Corp. v. Mississippi Division of Medicaid" on Justia Law

A resident of Madison County, Mississippi, received medical treatment at a hospital in Hinds County and later filed a claim with her health insurer, a foreign corporation doing business in the state. The insurer partially paid the claim but later, through its third-party administrator, asserted the hospital was out of network before eventually admitting it was in network. Despite repeated efforts by the insured to resolve the dispute, the insurer failed to pay the remaining balance or provide an explanation, ultimately stating the claim was untimely. The insured then sued the insurer and the administrator in Hinds County, seeking damages for breach of contract and related claims.The Circuit Court of Hinds County denied the insurer’s motion to dismiss or transfer venue to Madison County. Only the insurer sought and was granted an interlocutory appeal from this order. The administrator did not join the appeal.The Supreme Court of Mississippi reviewed the case, applying de novo review to the interpretation of the venue statute and abuse of discretion to the trial court’s venue ruling. The Court held that, under Mississippi Code Section 11-11-3(1)(a)(i), venue is proper where a substantial act or omission by the defendant caused the injury for which the plaintiff seeks redress. The Court found that the medical treatment in Hinds County was not a substantial event caused by the insurer that resulted in the alleged injury; rather, the alleged injury arose from the insurer’s acts or omissions related to the insurance contract, which were not tied to Hinds County. The Court overruled prior precedent to the extent it conflicted with this interpretation and concluded that venue was proper in Madison County. The judgment of the Hinds County Circuit Court was reversed and the case remanded for further proceedings in Madison County. View "National Health Insurance Company v. Lever" on Justia Law

Kyle Dew and Mossy Woods & Waters LLC were sued by Greenwood Leflore Consolidated School District and Mossy Brake Hunting Club, who claimed exclusive ownership of a portion of Mossy Lake located on sixteenth section land in Leflore County, Mississippi. The School District leases this section of the lake to the hunting club for recreational purposes and alleged that Dew trespassed on its property while on Mossy Lake. Dew countered that Mossy Lake is a public waterbody, and as a littoral landowner, he had the right to use the lake. He also argued that the public waters trust should take precedence over the sixteenth section trust.The Leflore County Chancery Court reviewed cross-motions for summary judgment and declaratory judgment. After a hearing and site visit, the chancery court found that the sixteenth section trust was superior to the public waters trust, quieted title to the relevant portion of Mossy Lake in favor of the School District and the hunting club, and enjoined Dew from using that section of the lake. The court also found Dew had not established adverse possession or a prescriptive right and rejected his claims for injunctive relief and attorneys’ fees.On appeal, the Supreme Court of Mississippi held that Mossy Lake, being navigable and an oxbow lake, is part of the public waters trust and never accrued to the sixteenth section land. The Court found that the School District does not have the right to exclude citizens who legally access the waters of Mossy Lake. The Supreme Court of Mississippi reversed the judgment of the Leflore County Chancery Court on all issues and remanded the case for further proceedings consistent with its opinion. View "Dew v. Greenwood Leflore Consolidated School District" on Justia Law

A commercial truck driver was stopped by police in Rankin County, Mississippi, for speeding and following too closely. During the stop, the officer noticed the driver was using paper logs instead of the electronic logs typically required for commercial vehicles, and observed inconsistencies in the logs. The driver, after initial denials, admitted to having over $100,000 in the vehicle, later specifying it was $225,000, which he claimed was for truck repairs or his life savings. The officer obtained consent to search the vehicle and found the cash packaged in multiple envelopes. Further investigation linked phone numbers provided by the driver to ongoing federal drug-trafficking investigations, and a trained narcotics dog showed interest in the cash. The State initiated civil forfeiture proceedings, alleging the money was connected to illegal drug activity.The Circuit Court of Rankin County held a bench trial, heard testimony from law enforcement and an expert in drug trafficking, and issued an order of forfeiture, finding by a preponderance of the evidence that the cash was connected to drug trafficking. The driver appealed, and the Mississippi Court of Appeals, in a split decision, reversed the trial court, concluding the State had not met its burden of proof under the relevant forfeiture statute.The Supreme Court of Mississippi reviewed the case on certiorari. Applying the substantial evidence/clearly erroneous standard, the court found that the trial court’s findings were supported by sufficient circumstantial evidence, including the manner of cash packaging, travel patterns, phone records, and the narcotics dog’s alert. The Supreme Court of Mississippi reversed the judgment of the Court of Appeals and reinstated and affirmed the judgment of the Circuit Court, holding that the State had met its burden to show the currency was more likely than not connected to illegal drug activity and thus subject to forfeiture. View "Chung v. State of Mississippi" on Justia Law