Justia Mississippi Supreme Court Opinion Summaries

In July 2017, Jeremy Thornhill said that he had injured his back while working. He sought workers’ compensation benefits from his employer, Walker-Hill and its insurance carrier, Zurich American Insurance Company of Illinois (collectively, Employer/Carrier), but the Employer/Carrier denied that Thornhill had sustained a compensable injury. Ultimately, the parties agreed to compromise and settled pursuant to Mississippi Code Section 71-3-29 (Rev. 2021). Thornhill submitted the settlement to the Mississippi Workers’ Compensation Commission for approval. After examining the application, the Commission approved the settlement and dismissed Thornhill’s case with prejudice. Pursuant to the settlement, Thornhill signed a general release,” which reserved his right to pursue a bad faith claim. Believing he had exhausted his administrative remedies, Thornhill filed a bad faith suit against the Employer/Carrier. The Employer/Carrier moved to dismiss, arguing that Thornhill had not exhausted administrative remedies—and that the circuit court lacked jurisdiction—because the Commission never made a factual finding that he was entitled to workers’ compensation benefits. The trial court granted the motion on that basis. The Court of Appeals reversed and remanded, finding that Thornhill indeed exhausted his administrative remedies and that the circuit court had jurisdiction to hear his bad faith claim. Finding no reversible error in the appellate court’s decision, the Mississippi Supreme Court affirmed. View "Thornhill v. Walker-Hill Environmental, et al." on Justia Law

The Mississippi Division of Medicaid (DOM) and Yalobusha County Nursing Home (YNH) disputed four costs submitted for reimbursement by YNH in its fiscal year 2013 Medicaid cost report. The DOM appealed a Chancery Court’s judgment ordering the DOM to reverse the four adjustments at issue. Because the DOM correctly interpreted the appropriate statutes and because its decisions were supported by substantial evidence, the Mississippi Supreme Court reversed the chancery court’s order and rendered judgment reinstating the decisions of the DOM. View "Mississippi Division of Medicaid v. Yalobusha County Nursing Home" on Justia Law

Long Beach Harbor Resort, LLC (the Resort), leased a parcel of land located on the Public Trust Tidelands from the City of Long Beach. The Mississippi Supreme Court was asked to determine whether the Resort is required to enter into a separate lease with the Secretary of State for the use of the tidelands property or whether the Resort already had a valid lease allowing use of the tidelands in question. The Court found that the State of Mississippi had, through its Boundary Agreement and Tidelands Lease with the City of Long Beach, ratified the prior lease entered into between the City and the Resort. Accordingly, the Court affirmed the chancery court’s grant of summary judgment in favor of the Resort and found that the Resort had a valid tidelands lease as ratified by the Secretary of State. View "Mississippi v. Long Beach Harbor Resort, LLC" on Justia Law

Lester Randle died in 2009, survived by his wife and son, Dorothy and Raymond. Lester had previously been married to Ruthie Randle. Two children were born of that marriage: Tumika and Sylvester, the Appellants. Ruthie and Lester divorced in 1977 when the children were very young. Lester died intestate. On May 7, 2018, Dorothy filed a petition for grant of letters of administration in which she noted that Lester’s “estate consist[ed] of no real property but ha[d] a potential claim for unliquidated damages arising out of” Lester’s death. The petition acknowledged the Appellants, as well as Dorothy and Raymond, as Lester’s heirs at law. Dorothy was appointed administrator on July 12, 2018. On November 19, 2018, Dorothy filed a petition for a determination of heirship, now asserting that the estate consisted of a claim for benefits against the manufacturer of Granuflow/Natural Lyte in the amount of $67,500.25 arising from Lester’s use of the prescription drug. The petition further claimed that the Appellants were “not heirs at law of Lester Randle and [were] not entitled to any of the settlement proceeds,” but rather they “were born to a married man, putative father,” and Ruthie. A summons by publication was submitted in the newspaper to any unknown heirs. The Court of Appeals affirmed a chancellor's adjudication that Dorothy and Raymond were Lester's only heirs at law. The issues this case presented for the Mississippi Supreme Court's review were: (1) whether the chancery court and the Court of Appeals incorrectly considered the settlement proceeds from a wrongful-death claim as an asset of the estate; and (2) whether the chancery court and the Court of Appeals incorrectly considered the petition to determine heirs under Mississippi Code Sections 91-1-1 to -31 (Rev. 2021) instead of a determination of wrongful-death beneficiaries under Mississippi Code Section 11-7-13 (Rev. 2019). The Supreme Court reversed the judgments of the Court of Appeals and chancery court and remanded this case to the chancery court to determine the wrongful-death beneficiaries of Lester under Section 11-7-13. View "Randle v. Randle" on Justia Law

Byram Café Group, LLC (BCG), moved for summary judgment against Eddie and Teresa Tucker in a premises-liability action arising from Eddie’s slip-and-fall accident. BCG sought judgment as a matter of law based on a lack of evidence supporting any of the elements of a slip-and-fall case. In response, the Tuckers argued that genuine issues of material fact existed as to dangerous conditions that may have caused Eddie’s fall. The circuit court denied BCG’s summary judgment motion. BCG sought interlocutory appeal, which the Mississippi Supreme Court granted. The issue the appeal presented was whether the Tuckers could survive a motion for summary judgment without producing evidence that a dangerous condition existed, that BCG caused the hypothetical dangerous condition, and that BCG knew or should have known about the dangerous condition. As a matter of law, the Supreme Court found the circuit court erred by denying BCG’s motion for summary judgment. Accordingly, the Court reversed and remanded the circuit court’s order. View "Byram Cafe Group, LLC v. Tucker" on Justia Law

The Mississippi Supreme Court granted Omar Humphrey’s petition for certiorari review of a Court of Appeals decision that dismissed his case. Humphrey’s complaint alleged that neither Steve Holts, police chief of Senatobia, nor John Champion, district attorney for the Seventeenth Circuit Court District, had responded to his letters requesting evidence and documents that related to his conviction made pursuant to the Public Records Act. Humphrey’s complaint alleged the same basis for his claims against both Holts and Champion and made very little, if any, distinction between the two other than referencing the individual letters sent to each defendant. The Court of Appeals dismissed the case for want of an appealable judgment. The Mississippi Supreme Court concluded the was, in fact, a final, appealable judgment and that the Court of Appeals should have decided Humphrey’s case on the merits. View "Humphrey v. Holts, et al." on Justia Law

Phillip and Anna Kennedy contracted with DIMA Homes, Inc., to build a house on property they owned in Marion County, Mississippi. The Kennedys failed to pay DIMA, and DIMA obtained a judgment, which it properly enrolled, creating a judgment lien on the property. The Kennedys then failed to pay property taxes, and in 2016, the land was sold at a tax sale to ACC Tax Sales Property, LLC. HL&C Marion, LCC, obtained the property from ACC. DIMA did not receive notice of the tax sale. In 2019, HL&C filed suit to quiet title. The chancery court ruled that the failure to give written notice of the sale to DIMA resulted in an extension of the two-year redemption period and set aside the tax sale. The Court of Appeals affirmed. The Mississippi Supreme Court granted certiorari and reversed the judgments of the Court of Appeals and the chancellor, and holding that no legal authority required notice of the tax sale to have been given to DIMA. Accordingly, judgment is rendered in favor of HL&C Marion. View "HL&C Marion, LLC v. DIMA Homes, Inc." on Justia Law

This case involved a medical-malpractice suit brought by Jalena and Brian Taylor against Jalena’s OB/GYN, Dr. Donielle Daigle, and her clinic, Premier Women’s Health, PLLC. In 2017, Jalena was admitted to Memorial Hospital of Gulfport in active labor preparing to give birth. After pushing for two and a half hours, the baby’s head became lodged in the mother’s pelvis, and it was determined that a caesarean section was necessary. Following delivery of the child, Jalena’s blood pressure dropped, and her pulse increased. The nurses worked to firm Jalena’s uterus post delivery, but she continued to have heavy clots and bleeding. Jalena was given a drug to tighten the uterus, and an OR team was called to be on standby in the event surgery became necessary. Dr. Daigle called the OR team off after Jalena’s bleeding was minimal, and her uterus remained completely firm. But Jalena’s heart rate remained extremely elevated. Dr. Daigle allowed Jalena to go back to her room, and she checked her again, and the uterus was firm. A minute or two later, Jalena sat up and felt a gush of blood. Dr. Daigle prepared to perform a hysterectomy, There was still bleeding from the cervical area, which doctors decided they needed to amputate. Even after doing so, there was still bleeding because of a laceration extending into the vagina. When the vagina was sutured and incorporated into the repair of the vaginal cuff, the bleeding finally stopped. The Taylors allege that Dr. Daigle failed to adequately treat Jalena and, as a result, she cannot have any more children. A five-day jury trial was held in January 2021, and the jury returned a twelve-to-zero verdict in favor of Dr. Daigle and Premier. On appeal, the Taylors argued the trial court committed reversible error by: (1) refusing to grant their cause challenges of patients of Dr. Daigle and Premier, thus failing to give them a right to a fair and impartial jury; and (2) failing to find a deviation from the standard of care for failing to perform a proper inspection of a genital tract laceration. The Mississippi Supreme Court affirmed the jury verdict because it was reached on factual evidence in favor of Dr. Daigle and Premier by an impartial jury. "All twelve of the jurors agreed on the verdict, and the verdict was not against the overwhelming weight of the evidence. It should not be disturbed." View "Taylor v. Premier Women's Health, PLLC, et al." on Justia Law

In September 2016, Christopher Strickland, Jr., a sophomore at Northwest Rankin High School, was at Choctaw Trails in Clinton, Mississippi, preparing to run a cross- country meet. Before the race, a wasp stung Christopher on the top of his head. According to Christopher, a lump began to form and his head felt tight, like it was swelling. Christopher told one of his coaches. According to affidavits submitted by the Rankin County School District (RCSD), two coaches and a registered nurse, who was there to watch her son race, examined Christopher’s head and found no evidence of a sting or adverse reaction. And Christopher assured them he was fine and wanted to run the race. But Christopher recalled only one coach examining him. And this coach told him to “man up” and run the race. Christopher ran the race. According to one of his coaches, she checked in on him at the mile marker. He responded that he was “okay, just hot.” According to Christopher, after the mile marker he began to feel dizzy. Then he fell, hitting his head. The same nurse attended to him. So did her husband, who was a neurologist. Christopher appeared to recover and rejoined his team after the race. But he later went to a doctor, who discovered injuries to his brain and spine. In January 2017, Christopher’s father, Christopher Strickland, Sr. (Strickland), sued RCSD on Christopher’s behalf. He alleged various breaches of duties in how RCSD employees acted both (1) after the wasp sting but before the race and (2) after Christopher’s fall. Specifically, Strickland alleged that, after the fall, RCSD employees failed to follow the district’s concussion protocol. The Mississippi Supreme Court surmised "much legal analysis has been aimed at whether the actions of two cross-country coaches were discretionary policy decisions entitled to immunity from suit under Mississippi Code Section 11-46-9(1)(d) (Rev. 2019)." But on certiorari review, the Court found this question to be moot: the alleged actions of the coaches do not establish any triable claim for negligence. For that reason, the Supreme Court affirmed the trial court’s grant of summary judgment to the Rankin County School District. View "Strickland v. Rankin County School District" on Justia Law

While driving a forklift at work, Lori Chandler was hit by another forklift and injured. She retained Turner & Associates to file a workers’ compensation claim. But Turner & Associates failed to file her claim within the statute of limitations. Adding to that, the firm’s case manager engaged in a year-and-a-half-long cover-up, which included false assurances of settlement negotiations, fake settlement offers, and a forged settlement letter purporting to be from Chandler’s former employer. Because of this professional negligence, Chandler filed a legal malpractice action. The only issue at trial was damages. The trial judge, sitting as fact-finder, concluded that Chandler had suffered a compensable work-related injury—an injury that caused her to lose her job and left her unemployed for nearly two years. Based on her hourly wage, the trial judge determined, had Turner & Associates timely filed Chandler’s workers’ compensation claim, Chandler could have reasonably recovered $50,000 in disability benefits. So the trial judge awarded her $50,000 in compensatory damages. The trial judge also awarded Chandler $100,000 in punitive damages against the case manager due to her egregious conduct. The Court of Appeals affirmed the punitive-damages award. But the court reversed and remanded the compensatory-damages award. Essentially, the Court of Appeals held that Chandler had failed to present sufficient medical evidence to support a $50,000 workers’ compensation claim. The Mississippi Supreme Court reversed the appellate court: "Were this a workers’ compensation case, we might agree with the Court of Appeals. But this is a legal malpractice case. And part of what Chandler lost, due to attorney negligence, was her ability to prove her work-related injury led to her temporary total disability. ... the Court of Appeals erred by applying exacting statutory requirements for a workers’ compensation claim to Chandler’s common-law legal malpractice claim." The Court reversed on the issue of compensatory damages and reinstated the trial judge’s $50,000 compensatory-damages award. Because this was the only issue for which Chandler sought certiorari review, it affirmed the remainder of the Court of Appeals’ decision, which affirmed the punitive-damages award but reversed and remanded the grant of partial summary judgment against attorney Angela Lairy in her individual capacity. View "Turner & Associates, PLLC, et al. v. Chandler" on Justia Law