Justia Mississippi Supreme Court Opinion Summaries

The DeSoto County School District entered into a contract with a private entity called the Mississippi High School Activities Association (“MHSAA”). The terms of the contract allowed MHSAA to decide whether School District students were eligible to play high school sports. In making its decisions, MHSAA applied its own rules and regulations, and neither the School District nor its school board had input into the process. In 2012, R.T. was a star quarterback for Wynne Public School in Wynne, Arkansas. His parents, the Trails, decided that a change of school districts would be in R.T.’s best interests, so in January 2013 they bought a house in Olive Branch and enrolled R.T. in Olive Branch High School. Their daughter was to remain in Wynne until the school year ended. MHSAA determined that R.T. was eligible to compete in spring sports and allowed R.T. to play baseball. MHSAA conditioned R.T.’s continuing eligibility on the Trails’ daughter also enrolling in the School District at the start of the 2013-2014 school year. But, because the Trails’ daughter did not want to leave her friends behind in Arkansas, the family decided that one parent would stay in Arkansas with their daughter, as they had done during the spring semester, and the other parent would move to Mississippi and remain with R.T. On the eve of the 2013 football season, MHSAA notified the school and R.T. that, under its interpretation of its rules and regulations, R.T. was ineligible to play because it had determined that his family had not made a bona fide move to the School District. Neither the School District nor Olive Branch High School appealed through MHSAA’s internal procedure, so the Trails immediately filed a petition for a temporary restraining order (TRO) and preliminary injunction in the DeSoto County Chancery Court. The chancellor signed an ex-parte order granting the TRO and revoking MHSAA’s adverse eligibility determination. "While it generally is true that high school students have no legally protected right to participate in high school athletics,25 once a school decides to create a sports program and establish eligibility rules, the school—or as in this case, MHSAA—has a duty to follow those rules; and it may be held accountable when it does not do so. . . . And where, as here, the school delegates its authority to control student eligibility through a contract with a private entity, we hold that students directly affected by the contract are third-party beneficiaries of that contract. For us to say otherwise would run contrary to the very reason for extracurricular activities, which is to enrich the educational experience of the students." R.T. had standing to challenge MHSAA's eligibility decision that prevented him from playing high school sports. The Court affirmed the chancery court in this case, and remanded the case for further proceedings. View "Mississippi High School Activities Association, Inc. v. R.T." on Justia Law

This appeal arose over a contract dispute between a yacht owner, an independent contractor hired to paint the yachts, and an unpaid paint supplier. The owner challenged a lien the unpaid paint supplier established and enforced on two multimilliondollar yachts under construction at the owner’s Gulfport shipyard. Upon review of the dispute, the Supreme Court affirmed the trial court’s grant of summary judgment in favor of the owner on a finding that privity did not exist between the owner and the unpaid paint supplier. View "In RE: Lien against M/Y Areti and M/Y Lady Linda: Trinity Yachts, LLC" on Justia Law

The McTaggarts filed suit against the former trustee and trust advisor of their family trust, alleging improper handling of their trust funds. The former trustee and trust advisor moved to dismiss the case or have the case stayed pending arbitration, based on an arbitration provision in a wealth-management agreement between the former trustee and trust advisor. The trial court found that, because the McTaggarts did not sign the agreement containing the arbitration provision and because the agreement specifically excluded nonsignatories, including third-party beneficiaries, the arbitration provision was not binding on the McTaggarts. The former trustee and trust advisor appealed. Finding no error, the Supreme Court affirmed. View "Pinnacle Trust Company, L.L.C., EFP Advisors, Inc. v. McTaggart" on Justia Law

In 2011, Gerald Collins granted Garrett Prestenbach a one-year option to purchase about 150 acres of Collins's farm and pasture land for $500,000. Prestenbach agreed to make a $25,000 down payment on the property and finance the remaining $475,000 through a combination of a $225,000 USDA loan and $250,000 financing agreement with Collins. The option contract included the following details: (1) a recital of $100 consideration; (2) a township-and-range description of the property; (3) a reference to the buyer's intent to obtain a USDA loan; (4) the total purchase price; and (5) a recital that the option was irrevocable for the first three months and, after three months, the option could be revoked by giving ten days' written notice. The parties also agreed that Collins would allow the USDA to inspect the property before closing. About a month after giving Prestenbach the option to purchase his land, another buyer offered to buy Collins's property immediately. Collins attempted to persuade Prestenbach to give up his option so he could sell to the other party, but Prestenbach refused and quickly recorded the option contract to prevent the sale. By early December, relations between Collins and Prestenbach had deteriorated. Collins's attorney sent Prestenbach a letter attempting to terminate the one-year option "upon the latter to occur of December 15th, its date of expiration, or ten (10) days after receipt of this notice." Prestenbach responded by hand-delivering a letter exercising his option to purchase. At that time, the USDA loan process was nearly complete, and on December 22, 2011, the USDA conditionally approved Prestenbach's loan. Prestenbach tried to set a closing date for the loan, but Collins refused to move forward with the closing. Claiming that the option to purchase had been terminated, Collins denied the USDA's request to inspect the property. He then filed a quiet-title action against Prestenbach. Prestenbach filed an answer and a counterclaim for specific performance, stating he was "ready, willing, and able" to close the deal. Both parties filed motions for summary judgment. The chancellor granted Collins's motion for summary judgment and denied Prestenbach's motion, finding that Prestenbach was not entitled to specific performance because, at the time he exercised his option, he could not pay the entire purchase price. Prestenbach appealed. The Supreme Court granted certiorari in this case "to correct a fundamental misunderstanding of the law on option contracts and specific performance." The option holder timely exercised his option to purchase and is entitled to specific performance, so the Court reversed and remanded. View "Prestenbach, Jr. v. Collins" on Justia Law

Columbus Cheer Company ("CCC") entered into a rental contract for the use of school facilities. Subsequently, CCC was informed that Columbus Municipal School District ("CMSD") would not honor the contract with CCC. CCC filed a complaint against CMSD. The complaint read in part: "[p]laintiff Columbus Cheer Company is a profit corporation licensed to due [sic] business in the state of Mississippi . . . ." The prayer sought judgment for plaintiff (CCC). Defendants filed their motion to dismiss or for summary judgment, asserting that CCC was an administratively dissolved corporation; therefore, CCC could not have entered into a valid contract with CMSD, and CCC did not possess the requisite legal status to initiate suit. The trial court entered an order granting Defendants' motion for summary judgment. CCC appealed, and the issues on appeal were: (1) whether a dissolved corporation could pursue a legal action; and if not, (2) could the corporation's shareholders pursue the same action in their own name? The Supreme Court answered both questions "no." View "Columbus Cheer Company v. City of Columbus" on Justia Law

This case stemmed from a family dispute. Eugene Barriffe, and his wife, Ernie, gave money to Ernie’s brother, Lawson Nelson, to start a landfill business in Jackson County. The Barriffes testified that Lawson approached them for an initial “investment” of $100,000—and later, a second “investment” of $65,000—into his idea to start a landfill business. In return, the Barriffes understood they were to receive two-thirds of the profits from the landfill business, with payments to begin when Eugene retired. Nelson denied the conversation and denied receiving the “investments” from the Barriffes. The Barriffes sued to receive compensation for the money they gave to Nelson to start the business business, and for improvements they made to an apartment on his land. The chancellor found that Nelson held the money and improvements in a constructive trust. But because the Barriffes failed to establish the existence of a constructive trust, the Supreme Court reversed in part and remanded for further proceedings. View "Barriffe v. Estate of Nelson" on Justia Law

Charles Blackmon and Dexter Booth sued Malaco, Inc.; N.J. Pockets, Inc.; and Callop Hampton (owner of Hamp’s Place Night Club) on a premises-liability claim. Plaintiffs settled with Malaco. At trial, the jury returned a verdict in favor of Hampton. Hampton filed a post-trial motion, requesting the trial court to impose sanctions against Blackmon, Booth, and their attorney for filing a frivolous lawsuit and to award attorney fees. The motion was denied, and Hampton appealed that judgment to the Supreme Court. Finding no abuse of discretion, the Supreme Court affirmed. View "Hampton v. Blackmon" on Justia Law

James Forbes settled a personal-injury action while he was represented by Louis St. Martin. Forbes later sued St. Martin, challenging the validity of his contingency-fee arrangement and the associated attorneys’ fees. The Chancery Court granted summary judgment to St. Martin; the Court of Appeals reversed the chancery court’s decision and remanded the case for further proceedings. Upon review of the matter, the Supreme Court reversed the Court of Appeals’ judgment, finding that summary judgment in favor of St. Martin was proper. View "In the Matter of the Estate of Louis St. Martin, Deceased: Forbes v. Hixson" on Justia Law

This case arose out of a fee dispute between associated attorneys arising out of mass-tort cases in Copiah County between 2005 and 2010. The first appeal arose out of a joint-venture agreement between Don Mitchell and the law firm of Sweet & Freeese, PLLC. The second appeal stemmed from an alleged oral referral agreement between McHugh Fuller Law Group, PLLC, and the members of the joint venture. The appellants in this consolidated appeal challenged the County Chancery Court’s denial of their motions to compel arbitration of claims brought against them by Mitchell and the McHugh Fuller Law Group, PLLC. Finding no error, the Supreme Court affirmed. View "Freese v. Mitchell" on Justia Law

In consolidated cases, thirty-two plaintiffs who signed delayed-deposit check agreements with Zippy Check Advance agreed that Zippy Check could pursue judicial remedies against them to collect the debt, while any and all of their claims would be relegated to arbitration. The circuit courts found the arbitration agreements to be unconscionable and denied Zippy Check’s motions to compel arbitration. The Court of Appeals affirmed as to one version of the agreement and reversed as to the other. Upon review, the Supreme Court found that both versions of the arbitration agreement were so one-sided that they were substantively unconscionable and unenforceable. The Court affirmed in part and reversed in part the judgment of the Court of Appeals and affirmed the judgments of the Circuit Court of Clarke County and the Circuit Court of Newton County. View "Caplin Enterprises, Inc. v. Arrington" on Justia Law