Justia Mississippi Supreme Court Opinion Summaries

Daryl Moore was employed by the Coahoma County School District Board as an at-will assistant coach for the high school boys’ basketball team during the 2019-2020 and 2020-2021 school years. He was paid $1,500 per year for his assistant coaching duties. Moore claimed that, at the request of the athletic director, he also performed the duties of the head coach for the junior-high boys’ basketball team but was never compensated for those additional responsibilities. He asserted that he was entitled to $5,000 for serving as the junior-high head coach over two years and brought suit against the Board for unjust enrichment and underpayment.The County Court of Coahoma County reviewed Moore’s claims after he filed suit for unpaid compensation. The Board moved for summary judgment, relying on Mississippi’s “minutes rule,” which requires that any binding contract with a public board be reflected in the board’s official minutes. The court denied summary judgment, finding that factual disputes remained regarding Moore’s coaching roles and compensation, and granted Moore additional time for discovery. The Board appealed, and the Supreme Court of Mississippi granted interlocutory review under Mississippi Rule of Appellate Procedure 5.The Supreme Court of Mississippi held that Moore’s claims were barred by the minutes rule because there was no evidence in the Board’s minutes of any agreement to pay Moore as head coach or to increase his compensation. The Court found that, since the Board’s minutes did not reflect approval of additional pay for head-coaching duties, Moore could not recover under theories of quantum meruit or unjust enrichment. The Supreme Court reversed the county court’s decision and rendered summary judgment in favor of the Board. View "Coahoma County School District Board of Education v. Moore" on Justia Law

After divorcing by mutual agreement, the parties executed a property settlement agreement incorporated into their judgment of divorce. The agreement required one party, Louise, to be responsible for a Trustmark National Bank judgment and to hold the other party, Corey, harmless from liability. Subsequently, Trustmark National Bank began garnishing Louise’s wages to satisfy the judgment. Later, Corey discovered a lien from the Trustmark judgment on property he received in the divorce. To complete a sale of that property, Corey paid the remaining balance of the judgment in a lump sum, without notifying Louise of the lien or his payment. Louise learned the judgment had been released but did not know Corey had paid it.Corey then filed a contempt action in Pike County Chancery Court, alleging that Louise willfully violated the property settlement agreement by failing to fully satisfy the debt and reimburse him. After a hearing, the chancellor held Louise in willful contempt, ordering her to pay Corey the amount he had paid to release the lien, plus interest, in a lump sum within ninety days, and to pay $4,000 in attorneys’ fees within sixty days. Louise appealed to the Mississippi Court of Appeals, which affirmed the chancellor’s decision, concluding the agreement required Louise to reimburse Corey and that the chancellor did not clearly err in finding contempt.The Supreme Court of Mississippi granted certiorari. It held that there was no clear and convincing evidence that Louise willfully or deliberately violated the court’s order, as she was paying the debt through wage garnishment and was unaware of Corey’s payment. The court also found the agreement was vague regarding the manner and timing of reimbursement. The Supreme Court reversed and rendered the contempt and attorneys’ fee awards, and remanded to the chancery court to determine the timing and manner of reimbursement. View "Gombako-Amos v. Amos" on Justia Law

Benard Hubbard II electronically signed an admissions packet and a stand-alone arbitration agreement for his father’s admission to Woodlands Rehabilitation and Healthcare Center in Clinton, Mississippi. At the time, Hubbard Sr. was competent and able to communicate with staff. Two years later, Hubbard Sr. filed a medical-negligence claim against the facility’s parent company, a physician, and a medical practice. The defendants moved to compel arbitration based on the agreement signed by Hubbard II. At the hearing, both parties acknowledged that Hubbard II did not have power of attorney or formal authority and that the arbitration agreement was separate from the admission itself. Hubbard II submitted an affidavit stating he signed without consulting or receiving authority from his father, and no evidence was presented to refute this.The Hinds County Circuit Court granted the motion to compel arbitration, expressing concern about Hubbard II contesting the agreement but failing to specify any factual basis for its decision or address the defendants’ request for additional discovery. The defendants subsequently conceded in the Supreme Court of Mississippi that the factual record was insufficient to affirm the trial court’s order and requested a remand for further findings.The Supreme Court of Mississippi reviewed the trial court’s decision de novo and found that the record lacked evidence establishing Hubbard II’s authority to bind his father to arbitration. The court also determined that the defendants had abandoned their motion for additional discovery by failing to secure a trial court ruling. Accordingly, the Supreme Court reversed the trial court’s order compelling arbitration and remanded the case for further proceedings consistent with its opinion. View "Hubbard v. Nexion Health at Clinton, Inc." on Justia Law

Mitchell Glenn Revette sought medical care from Dr. Andrew Mallette at The Surgical Clinic Associates, P.A. for abdominal pain and underwent surgery for diverticulitis in June 2021. He later returned for a follow-up surgery in January 2022, after which he died due to complications related to respiratory depression. His wife, Nitkia Revette, brought a wrongful death and medical negligence lawsuit on behalf of his estate, alleging that negligent anesthesia and pain management led to his death.The defendants, Dr. Mallette and the Clinic, moved to compel arbitration based on an arbitration agreement included in an intake packet mailed to Mitchell. The agreement was signed "Mitchell Revette," but during a hearing in the Hinds County Circuit Court, Nitkia testified that she signed her husband’s name without his knowledge or presence, and she stated she had no authority to sign for him. The Clinic’s staff testified that patients were required to sign such agreements personally. The circuit court found that Mitchell did not sign the arbitration agreement and that Nitkia lacked authority to bind him, thus ruling the agreement unenforceable and denying the motion to compel arbitration.On appeal, the Supreme Court of Mississippi reviewed the circuit court’s findings, applying a deferential standard to factual determinations and de novo review to the denial of arbitration. The Supreme Court affirmed the circuit court’s decision, holding that substantial evidence supported the findings that Nitkia lacked both actual and apparent authority to sign for Mitchell and that there was no basis for binding the estate via direct-benefits estoppel. The case was remanded to the circuit court for further proceedings. View "Mallette v. Revette" on Justia Law

A redevelopment project in Tunica County, Mississippi, involved a distressed property previously operated as a casino. The county sought to acquire the property from its private owner, TJM Properties, Inc., with plans to redevelop it into a convention center complex. Plaintiffs, including Don Hewitt, Advanced Technology Building Solutions, LLC (ATBS), and Tunica Hospitality & Entertainment, LLC (TH&E), invested significant sums in anticipation of becoming the developer and manager under a series of agreements and extensions. However, the purchase option was never exercised, and a senior lienholder ultimately foreclosed on the property.The Tunica County Chancery Court found that the plaintiffs never acquired title, held no enforceable lien, and were not parties to the key asset-purchase agreement. The court dismissed their claims with prejudice, holding that they lacked a legally cognizable property interest, standing to assert a claim, or entitlement to relief. Additionally, the chancery court enforced a previous agreed order requiring the plaintiffs to pay $200,000 to TJM for property maintenance, a payment that was never made.The Supreme Court of Mississippi reviewed the case and affirmed the chancery court’s dismissal of all claims with prejudice. The court held that the plaintiffs had no valid or enforceable lien on the property because they were not licensed contractors, performed no actual construction, and had previously waived any lien rights by consent order. The court also found no error in enforcing the $200,000 judgment and concluded that the plaintiffs lacked standing to challenge the transfer of funds between the county and TJM. The judgment of the Tunica County Chancery Court was therefore affirmed. View "Hewitt v. TJM Properties, Inc." on Justia Law

Two financial advisors entered into two agreements as part of a business transaction: an operating agreement establishing them as members of a wealth management firm and a purchase-and-sale contract under which one advisor would gradually buy out the other's ownership interest. The operating agreement contained a noncompete clause and provisions for mediation and arbitration. After the buyout concluded, the selling advisor remained employed with the company and could only be terminated for cause. In January 2024, he was terminated for cause and immediately began working at a competing firm within the restricted radius specified in the noncompete provision.Following his termination, the company and the buying advisor filed suit in the Circuit Court of Forrest County, alleging breach of contract and seeking, among other relief, a temporary restraining order and preliminary injunction to enforce the noncompete clause. The trial court granted the injunction and denied the selling advisor’s motions to dissolve the restraining order, to deny the injunction, and to compel mediation and/or arbitration. The trial court found that the noncompete clause remained binding and that the parties had not shown a clear intent to compel mediation or arbitration for this dispute, given specific contractual language.On appeal, the Supreme Court of Mississippi reviewed whether the noncompete provision was enforceable, whether the trial court erred in issuing the preliminary injunction, and whether the denial of the motion to compel mediation/arbitration was proper. The Court held that the noncompete provision was binding based on the evidence at the preliminary injunction stage, that the trial court did not err in granting the preliminary injunction, and that the mediation/arbitration provisions were not clearly applicable to this dispute. The Supreme Court of Mississippi affirmed the trial court’s order in all respects. View "Wiggins v. Southern Securities Group, LLC" on Justia Law

A resident of Madison County, Mississippi, received medical treatment at a hospital in Hinds County and later filed a claim with her health insurer, a foreign corporation doing business in the state. The insurer partially paid the claim but later, through its third-party administrator, asserted the hospital was out of network before eventually admitting it was in network. Despite repeated efforts by the insured to resolve the dispute, the insurer failed to pay the remaining balance or provide an explanation, ultimately stating the claim was untimely. The insured then sued the insurer and the administrator in Hinds County, seeking damages for breach of contract and related claims.The Circuit Court of Hinds County denied the insurer’s motion to dismiss or transfer venue to Madison County. Only the insurer sought and was granted an interlocutory appeal from this order. The administrator did not join the appeal.The Supreme Court of Mississippi reviewed the case, applying de novo review to the interpretation of the venue statute and abuse of discretion to the trial court’s venue ruling. The Court held that, under Mississippi Code Section 11-11-3(1)(a)(i), venue is proper where a substantial act or omission by the defendant caused the injury for which the plaintiff seeks redress. The Court found that the medical treatment in Hinds County was not a substantial event caused by the insurer that resulted in the alleged injury; rather, the alleged injury arose from the insurer’s acts or omissions related to the insurance contract, which were not tied to Hinds County. The Court overruled prior precedent to the extent it conflicted with this interpretation and concluded that venue was proper in Madison County. The judgment of the Hinds County Circuit Court was reversed and the case remanded for further proceedings in Madison County. View "National Health Insurance Company v. Lever" on Justia Law

Gloria Thompson and Deborah Dixon were former clients of Herbert Lee Jr., who represented them and others in a large settlement related to diet-drug litigation. As part of the settlement, a fee was paid into a multidistrict litigation (MDL) fund, with 45 percent of the fee coming from Lee and 55 percent from his clients. Later, a portion of the MDL fee was refunded. Lee distributed the refund by keeping 45 percent for himself and distributing the remainder per capita among his clients, which led to disputes over whether this was proper under the applicable MDL orders.After Thompson and Dixon challenged Lee’s distribution of the refund, the Circuit Court of Holmes County found that Lee had improperly allocated the refund and awarded damages to Thompson and Dixon. The Mississippi Supreme Court previously affirmed this judgment. However, the judgment expired in July 2021 without being renewed, and some of the refund money remained in escrow due to ongoing disputes.When Lee died, his estate was opened in the Hinds County Chancery Court. Sharon Gallagher-Lee, as administratrix, petitioned to bar claims by Thompson and Dixon, arguing the statute of limitations had expired. The chancellor agreed, found that the expired judgment barred their claims, and ordered the MDL refund to be paid entirely to Lee’s estate.The Supreme Court of Mississippi reviewed the case and held that the chancellor erred by ordering the full refund to the estate based on an expired judgment. The court concluded that, since the refund had been held in trust and the judgment had expired, the funds should be returned according to the original contributions: 45 percent to the estate and 55 percent to Thompson and Dixon. The order was reversed and the case remanded for distribution consistent with this holding. View "Thompson v. Estate of Lee" 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 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