Justia Mississippi Supreme Court Opinion Summaries

A man was admitted to a long-term healthcare facility by his wife, who signed all required admission documents, including an arbitration agreement. The arbitration agreement stated that all disputes related to the facility’s care would be resolved by binding arbitration, but it was not a condition of admission or continued care. After the man’s death, his wife, individually and on behalf of his wrongful death beneficiaries, sued the facility and two nurses, alleging improper care and treatment resulting in his death.The defendants moved to compel arbitration, contending there was a valid agreement and that the wife had the authority to enter into it as her husband’s healthcare surrogate, since he allegedly lacked capacity at admission. The wife countered that there had been no proper determination of her husband’s incapacity at the time of admission and, regardless, that signing an arbitration agreement was not a healthcare decision. The Hinds County Circuit Court denied the motion to compel arbitration, relying on precedent holding that a healthcare surrogate’s authority is limited to healthcare decisions, and that an arbitration agreement is not a healthcare decision unless it is an essential part of receiving care. The court found that, since arbitration was not a condition of admission or care, the wife lacked authority to bind her husband.On appeal, the Supreme Court of Mississippi reviewed the denial de novo. The Court reaffirmed that under Mississippi law, a surrogate’s authority extends only to healthcare decisions, and an arbitration agreement is only such a decision if required for admission or care. Because the arbitration agreement in this case was not a condition of admission or care, the wife lacked authority to execute it. The Supreme Court of Mississippi affirmed the trial court’s denial of the motion to compel arbitration and to stay proceedings, holding the arbitration agreement invalid and unenforceable. View "Manhattan Nursing and Rehabilitation Center, LLC v. Hawkins" on Justia Law

The case involves a personal injury claim arising from an automobile accident in which the plaintiff was rear-ended by the defendant while merging onto a roadway. Both parties testified that the collision caused minimal damage, and the plaintiff received brief medical attention before being released from care. The plaintiff had a prior history of back surgery but denied recent issues before the incident. The defendant admitted liability for the accident but contested whether his negligence was the proximate cause of the plaintiff's alleged injuries.The Desoto County Circuit Court presided over the trial. Prior to trial, the court granted in part the defendant’s motion to exclude “reptile theory” and “golden rule” arguments, preventing the plaintiff from making references at trial to the defendant’s personal sense of safety or knowledge of traffic rules in a way intended to evoke juror emotion. At trial, the court sustained objections to several questions by the plaintiff’s counsel regarding the defendant’s understanding of traffic rules and safety responsibilities. The jury was instructed that the defendant was negligent but that the plaintiff had to prove his negligence proximately caused her injuries. The jury returned a unanimous verdict for the defendant, finding the plaintiff failed to establish proximate cause. The plaintiff appealed, but did not file a motion for a new trial.The Supreme Court of Mississippi reviewed the case. It held that because the plaintiff did not file a motion for a new trial, appellate review of whether the jury’s verdict was against the overwhelming weight of the evidence was barred. The court also found that the trial court did not abuse its discretion by excluding the plaintiff’s “reptile theory” questioning, as such arguments were inadmissible under Mississippi Rules of Evidence 401 to 403. The judgment of the circuit court was affirmed. View "Greer v. Key" on Justia Law

After an evening involving alcohol, three men—Keith, his brother Dannie, and Bryant—traveled together in Dannie’s truck. The next morning, Bryant was found in the road with a fatal head injury. During the investigation, Dannie provided law enforcement with inconsistent stories but eventually stated that Keith struck Bryant on the head with a club-like object during an argument, after which Bryant did not recover. A search of Dannie’s truck revealed an object matching Dannie’s description. Other witnesses corroborated that the three men left together and that Bryant did not return. The medical examiner concluded that Bryant’s death was a homicide caused by blunt-force trauma.The Copiah County Circuit Court conducted a jury trial. The prosecution introduced autopsy photographs over defense objections, and Dannie testified, admitting his own inconsistent statements. The jury found Keith guilty of second-degree murder but deadlocked on sentencing, resulting in a statutorily mandated thirty-year sentence.On appeal to the Supreme Court of Mississippi, Keith challenged the admission of certain autopsy photographs, the sufficiency of the evidence (arguing that Dannie’s testimony was unreliable), and the propriety of the jury instructions on depraved-heart murder and culpable-negligence manslaughter. The Supreme Court of Mississippi held that the trial court did not abuse its discretion in admitting the photographs, as they supplemented the pathologist’s testimony and were probative given the disputed manner of death. The Court found that the jury was entitled to judge Dannie’s credibility and that the verdict was not against the overwhelming weight of the evidence. The Court also determined that the jury instructions, considered as a whole, properly explained the hierarchy and definitions of the offenses. Any possible error in the manslaughter instructions was deemed harmless, as the jury convicted Keith of murder. The Supreme Court of Mississippi affirmed Keith’s conviction and sentence. View "Goods v. State of Mississippi" on Justia Law

On the night of May 26, 2023, Undra Williams entered the Inferno Sports Bar and Nightclub in Columbus, Mississippi, where he was seen on surveillance footage wearing orange and blue. After an initial exchange of words with Devan Thompson, Williams left and later returned to the club. Witnesses testified that Williams drew a gun and shot Thompson multiple times, resulting in Thompson’s death. Three bystanders suffered gunshot wounds. Several witnesses, some of whom personally knew Williams, identified him both in surveillance footage and in court as the shooter. Nine shell casings were recovered from the scene, but the weapon was never found. Williams turned himself in two days later.After a jury trial in the Lowndes County Circuit Court, Williams was convicted of first-degree murder and three counts of aggravated assault. The State retired a fourth count of aggravated assault. Williams was sentenced to life imprisonment for the murder and three consecutive twenty-year terms for the aggravated assault convictions. His post-trial motion for judgment notwithstanding the verdict, or alternatively for a new trial, was denied by the Circuit Court.On appeal to the Supreme Court of Mississippi, Williams argued that the convictions were against the overwhelming weight of the evidence, citing unreliable eyewitness testimony and a lack of physical evidence. The Supreme Court of Mississippi held that the convictions were supported by compelling testimonial and video evidence and that it is within the jury’s province to resolve questions of witness credibility and evidentiary weight. The Court found no abuse of discretion by the trial court in denying the motion for a new trial and affirmed Williams’s convictions and sentences. View "Williams v. State of Mississippi" on Justia Law

On September 16, 2022, a police report was filed following the theft of a Glock 42 firearm stamped with the name “Hendricks.” Security footage led authorities to identify Tavion Pegues as the perpetrator, and an arrest warrant was issued. On February 8, 2023, law enforcement arrested Pegues at his sister’s home, where they recovered two firearms from a bedroom that Pegues occasionally used. Pegues’s sister testified that the firearms and associated items found in her son’s bedroom did not belong to her or her family, but belonged to Pegues, who often stayed there. Photographs and videos retrieved from Pegues’s cellphone showed him possessing one of the firearms shortly before the search. Pegues was indicted for armed robbery, possession of a firearm by a convicted felon, and possession of a stolen firearm, but the State proceeded only on the possession charge.The case was tried in the Circuit Court of Oktibbeha County, where a jury found Pegues guilty of possession of a firearm by a convicted felon. Pegues was sentenced as a habitual offender to life without parole. He subsequently moved for a judgment notwithstanding the verdict or for a new trial, but the trial court denied his motion.On appeal, the Supreme Court of Mississippi reviewed Pegues’s claims of prosecutorial misconduct and insufficiency of the evidence regarding constructive possession. The Court held that the State’s comments about Pegues’s failure to call his mother and nephew as witnesses, and its reference to his right to a trial, were not plain error because Pegues’s family members were more available to him than to the State, and the evidence against him was overwhelming. The Court also found the evidence sufficient to prove constructive possession, given Pegues’s connection to the firearms and the items found with them. The conviction and sentence were affirmed. View "Pegues v. State of Mississippi" on Justia Law

Jackson County Heart ASC, LLC submitted an application to the Mississippi State Department of Health (MSDH) seeking a certificate of need (CON) to establish a joint venture cardiac ambulatory surgical facility (JV-CASF) in Gautier, Mississippi. The proposed facility would provide outpatient cardiac catheterization services and was to be jointly owned by an acute care hospital and licensed cardiologists, as defined by the Mississippi State Health Plan. The application included supporting affidavits from cardiologists and financial projections, indicating that this would be the only freestanding outpatient JV-CASF in the Gulf Coast service area.MSDH staff recommended approval of the application, finding substantial compliance with relevant criteria. Following Singing River Health System’s request for a hearing, a hearing officer considered testimony and evidence from both sides, including expert witnesses and financial analyses. Although one supporting physician withdrew his endorsement at the hearing, the hearing officer ultimately recommended approval based on the entirety of the evidence. MSDH’s state health officer adopted these findings and issued a final order approving the CON. Singing River appealed to the Hinds County Chancery Court, which affirmed the approval after oral argument. Singing River then appealed to the Supreme Court of Mississippi.On appeal, the Supreme Court of Mississippi reviewed arguments regarding the adequacy of the application, economic viability, and potential adverse impacts on Singing River’s services and charitable care. Applying a highly deferential standard, the Court found substantial evidence supporting MSDH’s decision. The Court held that the application met the requirements of the State Health Plan and CON Review Manual, satisfied economic viability, and would not have a significant adverse impact on Singing River or its ability to provide charitable care. The Supreme Court affirmed MSDH’s approval of the CON. View "Singing River Health System v. Mississippi State Department of Health" on Justia Law

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