Justia Mississippi Supreme Court Opinion Summaries

In 2018, John Webb Pace, Jeannette Pace, and John Gregory Pace (the Paces) filed a complaint against Tiger Production Company, LLC, CCore Energy Management Company, LLC, Robert Marsh Nippes, and Harry Walters (collectively, “Tiger Production”). Each defendant filed a motion to dismiss the Paces’ claims for failure to exhaust their administrative remedies before the Mississippi Oil and Gas Board (MSOGB). After hearing oral arguments, the circuit court denied the motions to dismiss, determining that all of the Paces’ claims were based in common law and could not be remedied by the MSOGB. Tiger Production timely sought interlocutory appeal, which the Mississippi Supreme Court granted. After review, the Supreme Court found the circuit court was correct. The Court therefore affirmed the circuit court’s judgment and remanded the case to the circuit court for further proceedings. View "Tiger Production Company, LLC, et al. v. Pace" on Justia Law

Latoya Lawson brought an interlocutory appeal of a protective order entered by the Hinds County Circuit Court in a negligence case against the City of Jackson. In 2018, Lawson was injured when “she hit an unavoidable pothole” while driving her motorcycle on Woodrow Wilson Drive in Jackson, Mississippi. She alleged, inter alia, that the City was negligent in constructing and maintaining the roadway and that the City’s negligence caused her injuries. The trial court issued the order on review here due to Lawson’s lack of diligence in conducting discovery and her attempts to conduct discovery outside the agreed-upon deadlines. The order protected the City from having to respond to production requests that would be due after the discovery deadlines. Additionally, the order prohibited Lawson from making public records requests and from offering any public records she might obtain as evidence at trial. Lawson argued that the order was an abuse of the trial court’s discretion because it improperly restricted her right to access public records. The City argues that the trial court’s order was wholly within the court’s discretion as a discovery matter. The Mississippi Supreme Court affirmed a portion of the trial courts order protecting the City from having to respond to Lawson’s request for production of documents. It reversed, however, the portions of the order prohibiting Lawson from requesting public records and from offering those public records at trial. View "Lawson v. City of Jackson" on Justia Law

This case presented a question of whether Mississippi courts had personal jurisdiction over a South Korean battery manufacturer whose goods were in the stream of commerce in Mississippi. The Mississippi Plaintiff, Melissa Dilworth, was seriously injured when one of LG Chem Ltd.’s (LG Chem) lithium-ion batteries exploded in her vaping pen. LG Chem and its Georgia-based subsidiary, LG Chem America, argued successfully before the circuit court that they lacked sufficient minimum contacts with Mississippi to satisfy the constitutional standard for exercising personal jurisdiction over nonresident defendants. On appeal, the Mississippi Supreme Court found that manufacturer LG Chem purposefully availed itself of the market for its product in Mississippi such that the exercise of specific personal jurisdiction comported with due process principles. The Supreme Court also found that dismissal of subsidiary LG Chem America was premature; therefore, judgment was reversed and the matter remanded for jurisdictional discovery. View "Dilworth v. LG Chem, Ltd. et al." on Justia Law

The Court of Appeals affirmed a circuit court judgment which affirmed a county court judgment denying Julio Gordon’s motion to set aside a default judgment. The Mississippi Supreme Court granted Gordon’s petition for certiorari to consider the trial courts’ interpretation and application of Rule 13(k) of the Mississippi Rules of Civil Procedure. After review, the Supreme Court found the rule was misinterpreted and misapplied to the exclusion of Rule 15(a) of the Mississippi Rules of Civil Procedure, and that the county court erred by not setting aside the default judgment against Gordon. Accordingly, the Supreme Court reversed the Court of Appeals’ decision, reversed the circuit court, vacated the default judgment, and remanded this case back to the county court for further proceedings on the merits. View "Gordon v. Dickerson" on Justia Law

Tuwanda Williams and John Williams, Jr., filed a “Joint Motion to Dismiss Fault Grounds and Consent to Divorce on Grounds of Irreconcilable Differences” and submitted for review a judgment of divorce based on irreconcilable differences and a divorce agreement. Shortly thereafter, Tuwanda changed her mind. She withdrew her consent to the divorce agreement and also withdrew her consent to the divorce based on irreconcilable differences. John moved to enforce the divorce agreement. The chancellor found that Tuwanda timely withdrew her consent to the irreconcilable-differences divorce but that the divorce agreement was an enforceable contract binding on both Tuwanda and John. The chancellor granted John’s motion to enforce the divorce agreement and entered what he called a “final judgment” incorporating the agreement. Tuwanda appealed. Because the order entitled “final judgment” was not a final, appealable judgment, the Mississippi Supreme Court lacked jurisdiction to review the appeal. Accordingly, the appeal was dismissed. View "Williams v. Williams" on Justia Law

Nicholas Holliday appealed a circuit court decision, arguing the circuit court lacked subject matter jurisdiction to resolve an election contest brought by Robert Devaull concerning the 2020 Democratic Primary Runoff Election for Alderman, Ward I, in Aberdeen. Holliday relied on Devaull’s failure to comply with the statutory requirements of Mississippi Code Section 23-15-927. Additionally, Holliday argued that the trial court committed manifest error by determining that a special election was warranted. The Mississippi Supreme Court determined the trial court erred when it held that Devaull could amend his petition beyond the ten day deadline. Devaull failed to comply with the statutory requirement of filing a sworn copy of the complaint made to the Committee before the ten day deadline. The requirement of filing a sworn copy of the complaint was jurisdictional; therefore, the trial court lacked subject matter jurisdiction and without authority to order a new election. Judgment was reversed and rendered in favor of Holliday. View "In Re: Democratic Ward 1 Run-Off Election for the City of Aberdeen, Mississippi" on Justia Law

Jernigan Copeland Attorneys, PLLC (JCA) a Ridgeland, Mississippi law firm, filed suit against Shad White, in his official capacity as auditor for the state of Mississippi, seeking to recover damages for services rendered and for the reimbursement of costs and expenses owed to a public relations firm based on theories of breach of contract or, alternatively, promissory estoppel, quantum meruit, unjust enrichment, and indemnity. The Circuit Court found that, because discovery had not been completed in the case, genuine issues of material fact remained. Thus, it denied the office of the state auditor’s (OSA) motion to dismiss or, alternatively, for summary judgment. Because JCA failed to submit evidence creating a genuine issue of material fact that the employment contract complied with statutory requirements, and because JCA’s alternative claims were barred by the applicable statute of limitations, the Mississippi Supreme Court reversed the trial court’s denial of summary judgment. View "White v. Jernigan Copeland Attorneys, PLLC" on Justia Law

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