Justia Mississippi Supreme Court Opinion Summaries

After the death of Gary Wayne Johnson, who died without a will in 2021, his sister, Zoa Ann Manners, opened his estate and filed a creditor’s claim. Her claim was based on a document titled “Article of Agreement,” which Gary had prepared, signed, and delivered to her in 2002. Zoa Ann argued that this document created a contractual obligation for Gary, and subsequently his estate, to distribute a one-fourth interest in certain real property (specifically, Lots 12 and 13 of Lenzi Farms Subdivision) to her and her sisters, in accordance with their parents’ wills. The document was notarized but never recorded, and its language referenced the parents’ testamentary intentions.The Chancery Court of Marshall County held a hearing on Zoa Ann’s claim. After considering her testimony and the document, the chancery court found that the Article of Agreement was ambiguous, lacked sufficient clarity to convey a present interest in land, and did not meet the requirements of a deed or a contract. The court denied her claim against the estate. Zoa Ann appealed, and the Mississippi Court of Appeals reversed the chancery court’s decision, holding that the Article of Agreement did constitute a valid deed conveying a vested future interest in the property, and remanded the case for further proceedings.The Supreme Court of Mississippi reviewed the case on certiorari. It held that the Article of Agreement did not create a contractual obligation nor did it operate as a valid deed, as it failed to convey a present interest in the property and was testamentary in nature. The Supreme Court reversed the judgment of the Court of Appeals and reinstated and affirmed the judgment of the Chancery Court of Marshall County, denying Zoa Ann’s claim. View "In the Matter of the Estate of Gary Wayne Johnson v. The Estate of Gary Wayne Johnson" on Justia Law

Two parties, both experienced in the grocery business, negotiated the sale of a grocery store’s inventory, stock, and equipment for $175,000. The agreement was reached orally and memorialized with a handshake, but no written contract was signed. Following the oral agreement, the buyers took control of the store, closed it for remodeling, met with employees, and were publicly identified as the new owners. However, within two weeks, the buyers withdrew from the deal, citing issues with a third-party wholesaler. The sellers, having already closed the store and lost perishable goods, were unable to find another buyer and subsequently filed suit.The sellers brought ten claims in the Lee County Circuit Court, including breach of contract, estoppel, and negligent misrepresentation. The buyers moved to dismiss, arguing that the Statute of Frauds barred enforcement of the oral agreement because the sale involved goods valued over $500 and no signed writing existed. The circuit court agreed, dismissing the contract and estoppel-based claims, as well as the negligent misrepresentation claim, but allowed other claims to proceed. The sellers appealed the dismissal of the contract and estoppel claims.The Supreme Court of Mississippi reviewed the case de novo. It held that the sellers’ complaint plausibly invoked two exceptions to the Statute of Frauds under Mississippi law: the merchants’ exception and the part-performance exception. The Court found that, at the motion to dismiss stage, it could not determine as a matter of law that no valid contract existed under these exceptions. Therefore, the Supreme Court of Mississippi reversed the circuit court’s dismissal of claims (1) through (7) and remanded the case for further proceedings. View "Palmer's Grocery Inc. v. Chandler's JKE, Inc." on Justia Law

A roofing and repair company was audited by the Mississippi Department of Revenue (MDOR) for sales tax compliance. The first audit, covering 2011 to 2014, resulted in a modest assessment, with insurance-related repair jobs treated as nontaxable. A second audit, covering 2014 to 2017, led to a much larger assessment, including taxes on insurance-related jobs and a special city tax. The company challenged the assessment, arguing that certain jobs were not taxable and that the city tax should not apply to work performed outside city limits.After the second audit, the company appealed to MDOR’s Board of Review, which reduced the assessment. The company then appealed to the Board of Tax Appeals (BTA), which further reduced the tax owed and found in the company’s favor on three key issues: the city tax did not apply to jobs outside the city, a previously audited period should not be included in the new audit, and the company was entitled to relief for insurance jobs based on the prior audit’s treatment. The company paid the reduced assessment. MDOR, dissatisfied with the BTA’s reductions, appealed to the Chancery Court of Hinds County on those three issues. The company did not appeal or cross-appeal any issues, including an unresolved question about the taxability of certain jobs.The Chancery Court granted summary judgment to the company on all issues appealed by MDOR. The company then sought reconsideration, asking the court to address the unappealed, ancillary tax question, but the court denied the request, citing lack of jurisdiction. The Supreme Court of Mississippi affirmed, holding that only issues properly appealed from the BTA could be considered and that courts do not issue advisory opinions on unraised questions. The chancellor’s denial of post-judgment relief was not an abuse of discretion. View "Watkins Construction, Inc. v. Mississippi Department of Revenue" on Justia Law

A school resource officer employed by the Lee County School District was fatally injured while directing traffic on a state highway when a speeding motorist struck his parked vehicle, causing it to hit him. At the time, a warning sign intended to alert drivers to the school zone was allegedly inoperable. The officer’s wife received workers’ compensation benefits from his employer, but his two adult sons did not. The sons filed a wrongful death lawsuit against the Mississippi Department of Transportation (MDOT), alleging negligence in maintaining the warning sign and failing to warn of a dangerous condition.The case was heard in the Lee County Circuit Court. MDOT moved for summary judgment, arguing it was immune from suit under Mississippi Code Section 11-46-9(1)(l) because the decedent was a governmental employee whose injury was covered by workers’ compensation. The sons opposed, contending the statute did not bar their claims as wrongful death beneficiaries and, if it did, that the statute was unconstitutional. The trial court granted summary judgment to MDOT, finding the statute applied and provided immunity, and also upheld the statute’s constitutionality.On appeal, the Supreme Court of Mississippi reviewed the statutory interpretation and constitutional challenge de novo. The court held that wrongful death beneficiaries stand in the position of the decedent, and because the decedent could not have sued MDOT due to statutory immunity, neither could his sons. The court further held that Section 11-46-9(1)(l) does not violate the Mississippi Constitution’s remedy clause or the Equal Protection Clause of the U.S. Constitution, as the statute is rationally related to the legitimate purpose of protecting public funds. The Supreme Court of Mississippi affirmed the trial court’s orders granting summary judgment and upholding the statute’s constitutionality. View "Patterson v. State of Mississippi, ex rel. Attorney General Fitch" on Justia Law

A pet food manufacturer, Sunshine Mills, had a longstanding business relationship with Nutra-Blend, a supplier of animal nutrient products. For years, Sunshine Mills ordered a specific concentration of Vitamin D3 (Vitamin D3 7500) from Nutra-Blend for use in its dog food. In 2017, due to a miscommunication, Nutra-Blend shipped a different, much more concentrated product (Vitamin D3 500) instead. Sunshine Mills, unaware of the difference and believing Nutra-Blend only sold one type of Vitamin D3, accepted and used the product, resulting in several dogs developing Vitamin D toxicity, with some becoming ill or dying.After the incident, Sunshine Mills sued Nutra-Blend in the Lee County Circuit Court, alleging breach of contract, breach of implied warranty, a claim under the Mississippi Products Liability Act (MPLA), and common-law negligence. Nutra-Blend moved for summary judgment, arguing that all claims were subsumed by the MPLA and failed on other grounds. Sunshine Mills abandoned its tort-based claims, leaving only the contract-based claims. The Lee County Circuit Court granted summary judgment to Nutra-Blend on all claims, finding no genuine issues of material fact.The Supreme Court of Mississippi reviewed the case and held that the MPLA does not govern Sunshine Mills’ remaining claims because they do not allege damages caused by a defective product, but rather by breach of contract and implied warranty. The court clarified that the MPLA applies only to claims for damages caused by defective products, not to contract-based claims between commercial entities. The court also found that genuine issues of material fact existed regarding both the breach of contract and implied warranty claims, precluding summary judgment. Accordingly, the Supreme Court of Mississippi reversed the trial court’s decision and remanded the case for further proceedings. View "Sunshine Mills, Inc. v. Nutra-Blend, LLC" on Justia Law

The case concerns an altercation in an apartment between Sapireya Smith and Denise Neely. Smith, her boyfriend, and her brother shared the apartment, and Neely, who was married to Smith’s brother, entered to help him collect his belongings. A verbal argument between Smith and Neely escalated, culminating in Smith striking Neely in the head with a frying pan. Neely sustained significant injuries, including a fractured orbital bone and a deep laceration, requiring medical treatment and surgery. Smith admitted to throwing the pan but denied beating Neely with it, while another witness, Smith’s boyfriend, claimed not to have seen the fight’s initiation.The Circuit Court of Oktibbeha County conducted a jury trial, during which two of Neely’s treating physicians testified as lay witnesses about Neely’s injuries and treatment. Smith did not object to their testimony at trial. The jury found Smith guilty of aggravated assault, and she was sentenced to ten years in prison. Smith appealed, arguing that the physicians’ testimony constituted improper expert opinion and that her counsel was ineffective for failing to object.The Supreme Court of Mississippi reviewed the case. It found that while some of the treating nurse practitioner’s testimony about potential future complications from Neely’s injuries exceeded the permissible scope of lay opinion, the error was harmless given the overwhelming evidence of aggravated assault. The court also held that the radiologist’s testimony was permissible as lay opinion based on his direct observations and medical records. Regarding ineffective assistance of counsel, the court determined that the failure to object did not amount to constitutional ineffectiveness, as the decisions fell within trial strategy and did not prejudice Smith’s defense. The Supreme Court of Mississippi affirmed Smith’s conviction. View "Smith v. State of Mississippi" on Justia Law

A dispute arose when a private company constructed and operated a large LED billboard on property owned by a state agency, the Mississippi Department of Agriculture and Commerce (MDAC), within the City of Jackson. The billboard was built pursuant to a licensing agreement between MDAC and the company, Busby Outdoor, LLC, and was located on the State Fairgrounds. The City of Jackson, joined by other plaintiffs, claimed that the billboard violated the City’s sign and zoning ordinances because it was erected without a permit or variance and sought to enjoin its operation, also alleging it constituted a public nuisance.The Hinds County Chancery Court reviewed the matter after the City, The Lamar Company, LLC, and a former mayor filed suit. The court required MDAC to be added as a necessary party. After considering motions to dismiss and for summary judgment, the chancery court found that the City had standing but dismissed the other plaintiffs for lack of standing. The court held that MDAC and Busby were required to comply with the City’s sign ordinance, though it found the zoning ordinance did not apply due to a specific exemption for state institutions. The court further determined the billboard was a public nuisance because of its violation of the sign ordinance and issued an injunction halting its operation until compliance.On appeal, the Supreme Court of Mississippi reviewed the case de novo. The Court held that, absent a specific statutory provision subjecting the state or its agencies to municipal ordinances, the City could not enforce its sign ordinance against the state on state-owned property. The Court found that the relevant statutes did not expressly or by necessary implication grant the City such authority over MDAC’s property. Accordingly, the Supreme Court of Mississippi reversed the chancery court’s judgment, vacated the injunction, and rendered judgment in favor of MDAC and Busby, dismissing the City’s complaint with prejudice. View "Busby Outdoor LLC v. City of Jackson" on Justia Law

In this case, law enforcement responded to a 2017 homicide in which the victim was found shot in the head, with evidence suggesting robbery and drug involvement. The investigation initially stalled due to lack of leads, but in 2019, new information led to the identification of three suspects, including the appellant. The case remained unresolved until 2021, when the appellant was arrested on unrelated charges and questioned about the murder. During two recorded interviews, the appellant first denied involvement but later admitted to being present and participating in a plan to rob the victim. Other suspects were also interviewed, and ultimately, the appellant and three others were indicted for capital murder. Two co-defendants pleaded guilty to lesser charges, and another pleaded guilty to murder.The case was tried in the Alcorn County Circuit Court. The appellant moved to suppress his statements from both interviews, arguing they were involuntary due to intoxication and coercion, and that his right to counsel was violated. The trial court denied the motion after a suppression hearing, finding the statements voluntary and the right to counsel not unequivocally invoked. At trial, the appellant’s statements and testimony from co-defendants were admitted. The jury convicted the appellant of capital murder, and he was sentenced to life without parole. Post-trial motions for judgment notwithstanding the verdict or a new trial were denied.On appeal, the Supreme Court of Mississippi reviewed claims regarding the denial of the suppression motion, alleged improper witness vouching, the admission of a co-defendant’s prior statement, and ineffective assistance of counsel. The court held that the trial court did not abuse its discretion in admitting the appellant’s statements, found no reversible error in the handling of witness testimony, and determined that any procedural errors were either barred or did not amount to ineffective assistance. The conviction and sentence were affirmed. View "Reyes v. State" on Justia Law

A state port authority and a group of related companies entered into a series of letters of intent (LOIs) regarding the possible expansion and operation of a port facility. The final LOI, signed in December 2019, included provisions for confidentiality, exclusivity, and certain legally binding terms, but also stated that it was not a binding agreement to consummate the potential transaction. The port authority’s board approved the LOI and several subsequent extensions, but the board minutes did not include the terms or conditions of the LOI. After negotiations failed, the port authority terminated the LOI. The companies claimed significant losses and alleged the port authority had breached the LOI and misused confidential information.The Harrison County Circuit Court found that the LOI was unenforceable under Mississippi’s “minutes rule,” which requires that public board contracts be sufficiently detailed in the board’s official minutes. The court dismissed all claims based on the LOI, including breach of contract and quantum meruit, but allowed claims for unjust enrichment and misappropriation of trade secrets to proceed. Both parties sought interlocutory appeal, and the appeals were consolidated.The Supreme Court of Mississippi affirmed the lower court’s ruling that the LOI was unenforceable because the board minutes did not contain enough terms to determine the parties’ obligations, and held that the minutes rule was not superseded by the Open Meetings Act. The court also held that unjust enrichment, as an implied contract claim, was barred by the minutes rule and reversed the trial court’s denial of summary judgment on that claim. However, the court affirmed that the companies’ notice of claim regarding misappropriation of trade secrets was sufficient under the Mississippi Tort Claims Act. The case was remanded for further proceedings on the remaining claim. View "The Mississippi State Port Authority at Gulfport v. Yilport Holding A.S." on Justia Law

K.S. gave birth to her daughter, Jane, in August 2018 and struggled with ongoing methamphetamine abuse before, during, and after her pregnancy. Jane’s early life was marked by instability, with K.S. frequently leaving her in the care of relatives and exposing her to unsafe environments. After a series of rehabilitation attempts and relapses, Jane was adjudicated a neglected child by the Rankin County Youth Court in November 2019, and custody was transferred among family members. By early 2022, Jane was in the durable legal custody of M.F.D. and M.D., K.S.’s cousin and her husband.M.D. and M.F.D. filed a petition in the Rankin County Chancery Court in August 2022 to terminate K.S.’s parental rights and adopt Jane. Before trial, they requested the youth court to transfer jurisdiction to the chancery court, which the youth court granted, finding all matters resolved and the transfer in Jane’s best interest. The chancery court then held a trial, denied K.S.’s motion to dismiss for lack of jurisdiction, and terminated her parental rights based on abandonment, desertion, unfitness, and failure to provide for Jane’s needs. The court also found reunification was not in Jane’s best interest and subsequently granted the adoption. K.S. appealed the termination and later filed a Rule 60(b) motion to set aside the adoption, arguing lack of subject-matter jurisdiction, which was denied.The Supreme Court of Mississippi reviewed the consolidated appeals. It held that the chancery court had subject-matter jurisdiction to terminate K.S.’s parental rights because the youth court had formally relinquished jurisdiction, and no statute prohibited such transfer. The Court also found no manifest error in the termination decision, as substantial evidence supported the chancellor’s findings. Finally, the Court declined to adopt a rule requiring automatic stays of adoption proceedings pending appeals of termination orders. The judgments of the chancery court were affirmed. View "K.S. v. M.D. and M.F.D." on Justia Law