Justia Mississippi Supreme Court Opinion Summaries

Lyncoya Ratcliff was convicted of possession of a weapon by a felon and possession of a stolen firearm. He was pulled over by police for a broken headlight, and during the stop, officers found a stolen firearm in the vehicle. Ratcliff denied knowledge of the firearm but admitted ownership of a bag containing ammunition matching the stolen weapon. He was subsequently arrested and convicted on both charges.The Forrest County Circuit Court denied Ratcliff's motion for judgment notwithstanding the verdict, and he appealed. The Court of Appeals affirmed his convictions. Ratcliff then filed a petition for certiorari, which the Supreme Court of Mississippi granted, focusing solely on his conviction for possession of a stolen firearm.The Supreme Court of Mississippi reviewed the case de novo, considering whether the evidence was sufficient to support Ratcliff's conviction for possession of a stolen firearm. The court found that the evidence presented did not exclude the reasonable hypothesis that Ratcliff hid the weapon because he was a convicted felon, not because he knew it was stolen. The court noted that the State failed to provide sufficient evidence of Ratcliff's guilty knowledge that the firearm was stolen, as required by precedent cases such as Barton v. State.The Supreme Court of Mississippi reversed and rendered Ratcliff's conviction for possession of a stolen firearm, finding that the State did not meet its burden of proving guilty knowledge beyond a reasonable doubt. The court did not address Ratcliff's conviction for possession of a weapon by a felon, as it was not raised in the petition for certiorari. View "Ratcliff v. State of Mississippi" on Justia Law

The case involves Dr. Bryan C. Fagan, a surgeon, who called Judy Faulkner, a surgical scheduler, a vulgar name in the presence of several operating room personnel. Faulkner was not present during the incident but later heard about it from other staff members. She sued Fagan for defamation and intentional infliction of emotional distress, claiming that the vulgarity constituted an attack on her professional abilities and was therefore slander per se.The Lee County County Court held a bench trial and ruled in favor of Faulkner on the defamation claim, awarding her $30,000 in damages, but ruled in favor of Fagan on the intentional infliction of emotional distress claim. Fagan appealed the defamation ruling to the Lee County Circuit Court, which affirmed the County Court's decision. Fagan then appealed to the Court of Appeals, which reversed and rendered the judgments of the lower courts, holding that the trial court manifestly erred by finding the statement defamatory.The Supreme Court of Mississippi reviewed the case and affirmed the Court of Appeals' judgment on different grounds. The Supreme Court held that the trial court erred as a matter of law by denying Fagan’s motion for a directed verdict. The Court concluded that name-calling, even as offensive as the term used by Fagan, is not actionable as defamation in Mississippi. The Court found that Faulkner's proof fell short of establishing a prima facie case of defamation per se, as the vulgarity did not impute a want of professional capacity. Therefore, the Supreme Court reversed the judgments of the Lee County Circuit and County Courts. View "Fagan v. Faulkner" on Justia Law

Rudy Toler fired his handgun at four youths while traveling on Highway 90 between Pass Christian and Gulfport in 2021. This led to a high-speed chase during which Toler fired two more shots at pursuing officers. A Harrison County grand jury indicted Toler on ten felony charges, including multiple counts of aggravated assault and failure to stop for law enforcement. In 2023, a jury found Toler guilty on most counts, except for one count of aggravated assault against an officer.The Harrison County Circuit Court sentenced Toler to a total of forty years in prison. Toler appealed, arguing that the evidence was insufficient to support several of the convictions and that the trial court erred in excluding evidence of his peaceful character.The Supreme Court of Mississippi reviewed the case. The court found that the evidence was sufficient to support the convictions for aggravated assault against the officers and one count of aggravated assault against the youths. However, the court determined that the indictment was multiplicitous regarding the four counts of aggravated assault against the youths, as they were based on a single act of firing one shot. The court held that these counts should be merged into one.The Supreme Court of Mississippi affirmed the convictions in part, reversed in part, and remanded the case to the trial court to vacate the sentences for the four multiplicitous counts, merge them into one count, and resentence Toler accordingly. The court also found that the trial court did not abuse its discretion in excluding evidence of Toler’s peaceful character. View "Toler v. State of Mississippi" on Justia Law

Les Smith filed a petition for injunction and declaratory relief against Elizabeth and Rebecca Brockway to prevent them from installing a manufactured home on their property, alleging it violated restrictive covenants. The Brockways' property, Lot 13, was part of the Lakewood Village Subdivision, developed by Rainmaker’s Development Company, Inc. The restrictive covenants were referenced in the original warranty deed but were unsigned by the original grantor, Frank J. Steed.The Panola County Chancery Court denied Smith’s petition, finding the restrictive covenants unenforceable because they were not signed by the original grantor, as required by the covenants themselves. The court concluded that without the grantor's signature, the covenants never became a valid contractual obligation and thus did not run with the land.Smith appealed to the Supreme Court of Mississippi, arguing that the restrictive covenants were valid because they were attached to the original warranty deed, which was signed by the grantor. He contended that the covenants should be enforceable as they were intended to run with the land and that all subsequent purchasers, including the Brockways, had notice of them.The Supreme Court of Mississippi affirmed the chancellor’s decision, holding that the restrictive covenants were unenforceable because the original grantor failed to sign them. The court emphasized that the plain language of the covenants required the grantor’s signature to trigger their enforceability. Since the grantor did not sign the covenants, there was no intent to create covenants that would run with the land, and thus, they were never enforceable. View "Smith v. Brockway" on Justia Law

In August 2021, Jeremy Childress was involved in an incident where he threatened to commit suicide with a handgun. After being disarmed by a sheriff's deputy, Childress admitted to killing his girlfriend, Michelle Hester, by shooting her in the head. Hester's body was found in a utility room at her residence, with no weapons nearby. Childress claimed the shooting was accidental during an argument.The Harrison County Circuit Court conducted a jury trial, where Childress was convicted of first-degree murder. Childress moved for a directed verdict, arguing insufficient evidence for deliberate-design murder, but the motion was denied. He testified that the shooting was accidental, occurring during a heated argument where Hester allegedly threatened him with a knife and a gun. The jury was instructed on various charges, including first-degree murder, second-degree murder, and manslaughter, but ultimately found Childress guilty of first-degree murder.The Supreme Court of Mississippi reviewed the case, focusing on the sufficiency and weight of the evidence. The court held that the evidence supported the jury's verdict of deliberate-design murder. The court noted that Childress's own admissions and the physical evidence contradicted his claim of an accidental shooting. The court also found that the jury's verdict was not against the overwhelming weight of the evidence, as the jury had reasonably rejected Childress's version of events. Consequently, the Supreme Court of Mississippi affirmed Childress's conviction for first-degree murder. View "Childress v. State of Mississippi" on Justia Law

Alex and Jessica McGee were married in 2011, divorced in 2014, and remarried in 2017. They have three children. After their second separation in 2022, Alex filed for divorce on grounds of adultery. The Montgomery County Chancery Court granted the divorce, divided the marital property, and awarded joint legal and physical custody of the children. Jessica appealed, challenging the division of Alex’s retirement account and the custody arrangement.The Montgomery County Chancery Court classified and divided the marital property, including Alex’s 401(k) from the date of the second marriage to the date of separation. Jessica argued that the division should have included assets accumulated since their first marriage in 2011. The court found no evidence that the parties accumulated assets together during their separation and upheld the division from the second marriage. Jessica also contended that the chancellor improperly focused on her adultery in awarding joint custody and that the other factors favored her.The Supreme Court of Mississippi reviewed the case and affirmed the lower court’s decision. The court found that the chancellor properly classified and divided the marital property and applied the Ferguson factors correctly. The court also upheld the joint custody arrangement, noting that the chancellor considered the best interest of the children and did not overly focus on Jessica’s adultery. The court emphasized that the chancellor’s findings were supported by substantial evidence and that Jessica failed to demonstrate an inability to cooperate with Alex for joint custody. The judgment of the Montgomery County Chancery Court was affirmed. View "McGee v. McGee" on Justia Law

Eason Propane, LLC, purchased a new Freightliner propane delivery truck, which caught fire due to Empire Truck Sales, LLC's negligence during repairs. The fire caused significant damage to the truck, leading to extensive business losses for Eason Propane. Eason Propane sued Empire, seeking damages for the truck's diminished value, repair costs, lost profits, and other consequential damages.The case was tried in the Lamar County Circuit Court, where the jury found Empire liable and awarded Eason Propane $263,443.39 in damages. Empire moved for a new trial on damages or a remittitur, arguing that the jury's award was against the overwhelming weight of the evidence. The trial court denied Empire's motion, leading to this appeal.The Supreme Court of Mississippi reviewed the case and affirmed the trial court's decision. The court held that the jury's damages award was not manifestly unjust or so excessive as to shock the conscience. The court found that the evidence presented at trial supported the jury's findings, including the testimony of Eason Propane's experts regarding the truck's diminished value and lost profits. The court emphasized that it was within the jury's purview to weigh the credibility of the competing testimonies and evidence.The court concluded that the trial court did not abuse its discretion in denying Empire's motion for a new trial or remittitur. The jury's award of $112,698.46 for the truck's diminished value, $24,744.93 for repair costs, $120,000 for lost profits, and $6,000 for other consequential damages was affirmed. View "Stribling Equipment, LLC v. Eason Propane, LLC" on Justia Law

Jason Scarborough, a police officer, was involved in a car accident with Wanda Logan while responding to an emergency call. Scarborough was driving at 79 miles per hour in a 25-mile-per-hour residential zone with his emergency lights on but no siren. Logan, who was at a stop sign, pulled out in front of Scarborough, leading to a collision. Scarborough sustained severe injuries and sued Logan for negligence, seeking over $3 million in damages. The jury found Scarborough 60% at fault and Logan 40% at fault, awarding Scarborough $1.2 million, which the trial court reduced to $480,000 to reflect Scarborough's apportioned fault.The Rankin County Circuit Court allowed the deposition of Shane Remy, an accident reconstructionist, to be read at trial despite Logan's objection that Remy had not been qualified or tendered as an expert witness. Remy's testimony was crucial in attributing fault to Logan. The jury's verdict reflected a reduction based on Scarborough's fault, but the trial court further reduced the award, leading Scarborough to file a motion to alter or amend the judgment, which was denied.The Supreme Court of Mississippi reviewed the case and found that the trial court abused its discretion by allowing Remy's deposition without proper qualification as an expert witness. This error was not harmless, as Remy's testimony was the only evidence of Logan's fault aside from Scarborough's account. The court also found that the trial court erred in further reducing the jury's award, as the jury had already accounted for Scarborough's fault. Consequently, the Supreme Court of Mississippi reversed the trial court's judgment and remanded the case for a new trial, dismissing the direct appeal as moot. View "Scarborough v. Logan" on Justia Law

L.C. Slaughter and Isiac Jackson were removed from their positions as commissioners of the Canton Municipal Utilities Commission by the City of Canton Board of Aldermen. They appealed their removal to the Madison County Circuit Court, arguing that their removal was illegal and violated their due process rights. The circuit court agreed, finding the removal void as a matter of law, and reinstated them to their positions. The Board appealed this decision.The Mississippi Supreme Court affirmed the circuit court's decision, holding that the Board's removal of Slaughter and Jackson without notice and an opportunity to be heard was improper. The Court issued its mandate on April 6, 2023, affirming their reinstatement. Subsequently, on April 27, 2023, Slaughter and Jackson filed a petition for back pay in the same circuit court case, seeking compensation for the period they were removed.The circuit court denied the petition for back pay, citing lack of jurisdiction, as the issue of back pay was not raised before the mandate was issued. Slaughter and Jackson appealed this denial. The Mississippi Supreme Court reviewed the case de novo and held that the circuit court lost jurisdiction once the appeal was filed and did not regain it after the Supreme Court's mandate, which did not remand any issues for further consideration. Consequently, the circuit court's denial of the petition for back pay was affirmed. View "Slaughter v. City of Canton, Mississippi" on Justia Law

R.W. and J.R. are the biological parents of twins Rachel and Joshua, born prematurely on May 9, 2022. Both R.W. and the twins tested positive for amphetamines at birth. The Jackson County Youth Court placed the children in the custody of the Mississippi Department of Child Protection Services (CPS) and later adjudicated them as neglected children. The court also ruled that CPS could bypass reasonable efforts to reunify the twins with their parents. R.W. and J.R. appealed this decision.The Jackson County Youth Court initially held an emergency custody hearing, followed by an adjudication hearing where the twins were declared neglected. The court found that R.W. had a history of substance abuse and had previously lost custody of her other children. J.R. was incarcerated for failing to register as a sex offender. The court ruled that CPS could bypass efforts to reunify the children with their parents due to the parents' history and current circumstances. R.W. and J.R. raised issues on appeal regarding jurisdiction, venue, and the sufficiency of evidence supporting the neglect adjudication and the bypass of reunification efforts.The Supreme Court of Mississippi reviewed the case and affirmed the youth court's judgment. The court held that the youth court had both subject-matter and personal jurisdiction, and that Jackson County was the proper venue. The evidence presented, including the positive drug tests and the parents' histories, was sufficient to support the adjudication of neglect. The court also found that bypassing reasonable efforts to reunify the children with their parents was justified based on the parents' past terminations of parental rights and J.R.'s criminal history. The Supreme Court of Mississippi affirmed the youth court's decision. View "R.W. v. Mississippi Department of Child Protection Services" on Justia Law