Justia Mississippi Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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Defendant Tyrell Williams was convicted of sexual battery and sentenced to twenty years in the custody of the Mississippi Department of Corrections (MDOC). On appeal, he argued that he did not knowingly waive his constitutional rights, and the trial court therefore erred in denying his motion to suppress his inculpatory statement. Because the trial judge applied an incorrect legal standard at the suppression hearing, the Supreme Court reversed and remanded the case for a new suppression hearing and a new trial. View "Williams v. Mississippi" on Justia Law

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In a case consolidating the competing annexation petitions of Biloxi and D’Iberville, the chancellor ultimately awarded each city a reduced area from that requested, determining that it was unreasonable for either city to annex the entire area requested, and then determining that it was reasonable to award each city a smaller, reduced area. Both cities appeaedl this decision, and Biloxi raised jurisdictional issues for the first time on appeal. Because Biloxi raised personal jurisdiction on behalf of third parties, and because Biloxi failed to raise this issue at the trial-court level, the Supreme Court found that Biloxi not only lacked standing to raise this issue, it also waived it. Further, because the chancellor’s decision awarding each city a reduced area was reasonable and supported by substantial evidence, the Supreme Court affirmed the annexations as modified by the chancellor. View "In The Matter of the Enlarging, Extending and Defining the Corporate Limits and Boundaries of the City of Biloxi" on Justia Law

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Rico Veazy and Brandon Mosley were convicted of armed robbery and were sentenced to eight and ten years, respectively, in the custody of the Mississippi Department of Corrections after being tried together in circuit court. The robbery involved a vehicle belonging to Veazy but undergoing repairs by mechanic Jimmy Smith, who testified that the vehicle was taken from his repair shop by gunpoint. Finding no merit in any of the defendants' issues raised on appeal, the Supreme Court affirmed the circuit court's judgment. View "Veazy v. Mississippi" on Justia Law

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KCC, Inc., d/b/a Vital Care of Meridian (Vital Care) filed a complaint against the Mississippi State and School Employees' Life and Health Plan ("the Plan") and the Plan’s pharmacy benefits manager, Catalyst Rx, alleging that the Plan and Catalyst had violated Mississippi Code Section 83-9-6 by designating Walgreens Pharmacy as the sole provider of specialty pharmacy services. Later, Vital Care moved for partial summary judgment on the question of whether Section 83-9-6 applied to the Plan. The Chancery Court granted Vital Care’s motion for partial summary judgment, and the Plan and Catalyst appealed. Upon review of the applicable statute, the Supreme Court found that Section 83-9-6 applied to the Plan because it applies to "all health benefit plans providing pharmaceutical services benefits, including prescription drugs, to any resident of Mississippi" and was not ambiguous. View "Mississippi State & School Employees' Life and Health Plan v. KCC, Inc." on Justia Law

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In a slip-and-fall case, Laura Karpinsky alleged that she sustained injuries when she fell in a puddle in a shopping mall. The Circuit Court found that Karpinsky had failed to offer any evidence that her fall was caused by negligence attributable to the Defendants, and entered summary judgment against her. The Court of Appeals found that the circuit court had erred and reversed the summary judgment order. The Supreme Court granted certiorari and, finding that the circuit court properly granted summary judgment in this case, reversed the Court of Appeals and reinstated and affirmed the order of the circuit court. View "Karpinsky v. American National Insurance Company " on Justia Law

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Three main issues were raised on appeal to the Supreme Court in this case: (1) whether a school district is liable for oil and gas severance taxes on its royalty interests derived from oil and gas production on sixteenth-section land (the chancellor ruled that it is not); (2) whether the statute of limitations restricts the time period in which a school district can seek a refund of severance taxes that it had paid erroneously (the chancellor ruled that a three-year statute of limitations applied to any refund claims); and (3) whether a school district is liable for administrative expense taxes on its royalty interests derived from oil and gas production on sixteenth-section land (the chancellor ruled that it is). Upon review of the applicable code and in consideration of the arguments of the parties to this case, the Supreme Court found that the chancellor's judgment should be affirmed in part and reversed in part: (1) school districts are not liable for oil and gas severance taxes on sixteenth-section royalty interests: school districts, as political subdivisions of the state, are not included within the definition of "persons" made subject to these taxes; (2) pursuant to the Mississippi Constitution, statutes of limitation in civil causes do not run against the state or its subdivisions; and (3) school districts are liable for administrative expense taxes on sixteenth-section royalty interests: "[t]hese assessments are 'fees,' not 'taxes'; the Legislature has expressly made the state and its subdivisions subject to these fees; and no constitutional provision or other law is violated by requiring school districts to pay them." View "Jones County School District v. Mississippi Department of Revenue" on Justia Law

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John Stubbs was awarded damages for breach of contract after he sued Martin and Valerie Falkner to enforce a construction lien on their home. The Court of Appeals affirmed the circuit court's judgment, but reversed its award of attorney's fees and prejudgment interest, finding that Stubbs's recovery was based in quantum meruit and, thus, attorney's fees and prejudgment interest were unavailable remedies. Stubbs petitioned for certiorari, arguing that the Court of Appeals failed to consider various statutory grounds for an award of attorney's fees. Although the Court of Appeals did not discuss the statutes Stubbs raised, the Supreme Court found that those statutes provided an insufficient basis for an award of either prejudgment interest or attorney's fees in this case. The Court affirmed the Court of Appeals' decision and the judgment of the Circuit Court. View "Falkner v. Stubbs" on Justia Law

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Freddie Webber, Jr., was convicted of the sale or transfer of cocaine and was sentenced as a habitual offender to a term of thirty years in the custody of the Mississippi Department of Corrections (MDOC) without eligibility for probation or parole. Finding no error, the Supreme Court affirmed Webber's conviction and sentence. View "Webber v. Mississippi" on Justia Law

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Alexander Gardner sued the City of Jackson, alleging that he had suffered a broken leg when one of the City's police officers forced him to sit down while in handcuffs. The City filed for summary judgment, which was denied by the trial court. On review of the City's interlocutory appeal, the Supreme Court reversed the trial court's denial of summary judgment, finding that the officer's conduct did not rise to the level of reckless disregard for Gardner's safety and well-being. View "City of Jackson v. Gardner" on Justia Law

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Following a jury trial, Talib Hannah was convicted of possession of cocaine with intent. On appeal, he raised two issues: (1) whether the circuit court abused its discretion in denying Hannah's "Motion for the State to Disclose the Identity of Its Confidential Informant;" and (2) whether the circuit court abused its discretion in denying Hannah's motion for continuance. As Hannah's Sixth Amendment right to compulsory process to call a witness was not recognized, the Supreme Court reversed his conviction and sentence and remanded the case for a new trial. View "Hannah v. Mississippi" on Justia Law