Justia Mississippi Supreme Court Opinion Summaries

Mark Johnson sued the Clarksdale Public Utilities Authority (CPU) and its members in federal district court, alleging he was fired for reporting inefficiency and incompetence to the state auditor. His initial complaint asserted retaliation under the Mississippi Whistleblower Protection Act (MWPA), later amended to include First Amendment retaliation and breach of contract. The defendants moved for judgment on the pleadings, which the district court granted, holding that Johnson failed to comply with the Mississippi Tort Claims Act (MTCA) notice requirements and that the MWPA claim was barred by the MTCA’s one-year statute of limitations. The court also found Johnson’s First Amendment and breach-of-contract claims time-barred.The United States Court of Appeals for the Fifth Circuit reviewed the case, focusing on whether the MTCA’s procedural requirements apply to MWPA claims. The defendants argued that the MTCA’s broad application and limited immunity waiver necessitate compliance with its procedural requirements for MWPA claims. Johnson countered that the MWPA provides a separate right to monetary relief and should not be subject to the MTCA’s requirements.The Supreme Court of Mississippi reviewed the certified question from the Fifth Circuit. The court concluded that the MWPA is a remedial statute separate from the MTCA. The MWPA does not prescribe a statute of limitations or notice requirement, and the reference to the MTCA’s damages cap does not incorporate its procedural requirements. Therefore, the court held that MWPA claims are not subject to the MTCA’s statute of limitations and notice requirements. The certified question was answered accordingly. View "Johnson v. Miller" on Justia Law

L.C. Slaughter and Isiac Jackson were removed from their positions as commissioners of the Canton Municipal Utilities Commission by the City of Canton Board of Aldermen. They appealed their removal to the Madison County Circuit Court, arguing that their removal was illegal and violated their due process rights. The circuit court agreed, finding the removal void as a matter of law, and reinstated them to their positions. The Board appealed this decision.The Mississippi Supreme Court affirmed the circuit court's decision, holding that the Board's removal of Slaughter and Jackson without notice and an opportunity to be heard was improper. The Court issued its mandate on April 6, 2023, affirming their reinstatement. Subsequently, on April 27, 2023, Slaughter and Jackson filed a petition for back pay in the same circuit court case, seeking compensation for the period they were removed.The circuit court denied the petition for back pay, citing lack of jurisdiction, as the issue of back pay was not raised before the mandate was issued. Slaughter and Jackson appealed this denial. The Mississippi Supreme Court reviewed the case de novo and held that the circuit court lost jurisdiction once the appeal was filed and did not regain it after the Supreme Court's mandate, which did not remand any issues for further consideration. Consequently, the circuit court's denial of the petition for back pay was affirmed. View "Slaughter v. City of Canton, Mississippi" on Justia Law

The Mississippi Public Service Commission (the Commission) authorized a rate increase for Entergy Mississippi, LLC (Entergy) based on a joint stipulation with the Mississippi Public Utilities Staff (the Staff). Rankin County, an Entergy customer, intervened, disputing the exclusion of unbilled revenue from Entergy’s operating expenses. The Commission found substantial evidence supporting the rate increase and deemed new issues raised by Rankin County on appeal as waived.Rankin County intervened in the Commission’s proceedings, challenging the exclusion of unbilled revenue from Entergy’s operating income. The Commission held a public hearing, but Rankin County did not present admissible evidence. The Commission approved the rate changes, including an Annual Rate Adjustment and an Interim Rate Adjustment, based on Entergy’s financial data and the Formula Rate Plan. Rankin County appealed directly to the Supreme Court of Mississippi without seeking rehearing from the Commission.The Supreme Court of Mississippi affirmed the Commission’s order, finding that the exclusion of unbilled revenue was reasonable and supported by substantial evidence. The court held that Rankin County waived new issues raised on appeal by not presenting them to the Commission. The court also found no merit in Rankin County’s arguments regarding the recalculation of net rate adjustments, the application of the 4 percent cap on revenue increases, and the management of Entergy’s confidential records. The Commission’s order was affirmed as it complied with statutory and regulatory procedures, and the rate adjustments were not arbitrary or capricious. View "Rankin County, Mississippi v. Mississippi Public Service Commission" on Justia Law

Ricardo Jones sued the City of Jackson for injuries sustained from driving into a pothole. Before filing the lawsuit, Jones sent certified letters to the mayor and city council members but did not send a notice of claim to the city clerk, as required by the Mississippi Tort Claims Act (MTCA).The Hinds County Circuit Court denied the City’s motion for summary judgment, which sought dismissal of Jones’s claims due to his failure to comply with the MTCA’s presuit notice requirement. The City then petitioned the Supreme Court of Mississippi for an interlocutory appeal.The Supreme Court of Mississippi reviewed the case de novo and found that Jones did not comply with the mandatory requirement to serve notice on the city clerk. The court held that the MTCA’s presuit notice requirement is clear and mandatory, and serving notice on the mayor or city council members does not suffice. Consequently, the court reversed the trial court’s decision and rendered judgment in favor of the City, dismissing all of Jones’s claims. View "The City of Jackson, Mississippi v. Jones" on Justia Law

The case revolves around Katherine Harris, who was convicted for aggravated DUI. While driving with a blood-alcohol concentration (BAC) twice the legal limit, Harris crashed into a deputy sheriff and his patrol vehicle, causing severe injuries to the deputy. Before trial, Harris requested public funds to hire her own experts, a toxicologist and an accident reconstructionist, to counter the State’s evidence. However, her blood sample, which she had not requested to be preserved, had been destroyed according to routine procedure nine months after testing. The judge denied her requests for expert funding, finding them broad and theoretical, and Harris failed to articulate concrete reasons how these proposed independent experts would specifically assist her defense.In Mississippi, the discretion to grant or deny an indigent defendant funds to retain an independent expert lies with the trial court. The court found that Harris failed to articulate how her own experts would actually assist her defense. Furthermore, the State’s case did not rely exclusively on these two experts and her BAC. The State called additional witnesses who established the patrol car was clearly visible with its blue lights flashing, and multiple other vehicles successfully passed the patrol car before Harris slammed into it. Witnesses also testified Harris smelled like alcohol, failed a field sobriety test, admitted she had been drinking, and tested positive for alcohol on a portable breathalyzer at the scene.The Supreme Court of Mississippi affirmed Harris’s conviction and sentence, discerning no abuse of discretion in the judge’s denial of Harris’s request for expert funds. Based on the overwhelming evidence supporting Harris’s aggravated DUI conviction, the judge’s discretionary denial, even if erroneous, was not so prejudicial as to render her trial fundamentally unfair. View "Harris v. State of Mississippi" on Justia Law

Felissa Jones, the mother of an elementary school student, reported to the Mississippi Department of Child Protection Services (MDCPS) that her son had suffered abuse and neglect by staff at his school. MDCPS responded that it does not investigate reports of abuse at school. Jones then sued MDCPS, seeking declaratory and injunctive relief related to MDCPS’s policy that the agency does not investigate allegations of abuse in out-of-home settings such as schools.The Hinds County Chancery Court denied Jones's motion for a judgment in her favor on the pleadings and granted MDCPS's motion for a judgment on the pleadings, dismissing Jones's complaint. The court ruled that Jones's request for declaratory relief related to MDCPS’s former intake policy was moot because the policy was no longer in effect. It also ruled that the current intake policy does not violate the relevant statutes, but instead conforms to the statutory mandate to refer allegations of child abuse in out-of-home settings to local law enforcement.In the Supreme Court of Mississippi, Jones appealed the lower court's decisions. The court affirmed the lower court's rulings, stating that MDCPS does not have a duty to investigate reports of abuse in out-of-home settings, such as schools, because children who are mistreated by school staff do not fall under the youth court’s limited jurisdiction. The court also found that Jones's claim for declaratory relief from the amended policy had no merit because the policy tracks the relevant statutes. View "Jones v. Department of Child Protection Services" on Justia Law

In January 2020, Tiffany McClure, a probation officer, responded to a call for assistance during riots at the state penitentiary at Parchman. She alleges that the Mississippi Department of Corrections (MDOC) failed to pay her the promised overtime wages. This case is part of a series of actions filed by probation and parole officers seeking unpaid wages for their overtime work with the MDOC. The main question is whether Mississippi courts have jurisdiction to hear state employees’ claims against their employers for breach of contract.The MDOC argued that the Hinds County County Court erred by not dismissing McClure’s claims due to lack of subject matter jurisdiction. They contended that employment-related grievances are exclusively reviewed by the Employee Appeals Board, and any non-grievable claims have no right to relief under state law. McClure agreed that her claims were non-grievable, but asserted that the Hinds County County Court was the only forum that could provide relief.The Supreme Court of Mississippi affirmed the trial court’s ruling, stating that the Mississippi Constitution vests original jurisdiction with the circuit courts, and there are no adequate administrative remedies for McClure’s breach of contract and constitutional claims. However, the court noted that its holding was narrowly tailored to the specific facts of this case. The court also affirmed the Hinds County County Court's exercise of jurisdiction over the matter and remanded the case for further proceedings. View "Mississippi Department of Corrections v. McClure" on Justia Law

A fire broke out at Victor Young's property in Yazoo City, Mississippi, and spread to Kenneth Hampton's property. The Yazoo City Fire Department struggled to extinguish the fire due to a lack of tank water and difficulty connecting to a nearby fire hydrant. As a result, Young's property was completely destroyed, and Hampton's property was significantly damaged. Hampton, who was not physically injured during the fire, suffered a cardiac event and subsequent stroke three days later. Hampton and Young sued Yazoo City, alleging negligence and reckless disregard in failing to provide the necessary knowledge and equipment to fight fires, failing to properly train and supervise its firefighters, and failing to adequately maintain its fire hydrant system.The Yazoo County Circuit Court denied Yazoo City's motion for summary judgment, ruling that the questions of the city's immunity under the Mississippi Tort Claims Act (MTCA) for property damage and personal injury liability could not be answered without additional discovery. The city appealed this decision, arguing that it was immune from both property damage and personal injury liability under the MTCA.The Supreme Court of Mississippi reversed the lower court's decision. The court found that Yazoo City was immune from property damage liability because the plaintiffs did not allege that the city acted with reckless disregard for the safety and well-being of any person, as required by the MTCA. The court also found that the city was immune from personal injury liability because Hampton's claim linked the property damage to his personal injury, but did not argue that the fire department acted in reckless disregard of his safety and well-being. The court concluded that Yazoo City was immune from both property damage and personal injury liability under the MTCA, and therefore, the lower court improperly denied the city's motion for summary judgment. View "Yazoo City v. Hampton" on Justia Law

The case revolves around the suicide of Donnie Clay while he was detained in the Tunica County Jail. Barbara Clay, Donnie's wife, and Whitney Jackson, Donnie's girlfriend, filed a wrongful death lawsuit against Sheriff K.C. Hamp and Tunica County. The plaintiffs alleged that the defendants violated Donnie's Fourteenth Amendment rights under 42 U.S.C. § 1983 by failing to prevent his suicide. The plaintiffs claimed that the defendants were aware or should have been aware of Donnie's vulnerability to suicide due to his history of multiple suicide attempts while detained in the jail, and that they failed to take action to prevent this risk.The defendants filed a combined motion for summary judgment, arguing that Sheriff Hamp was entitled to qualified immunity and that the County could not be held liable under § 1983 as the plaintiffs failed to establish that a policy or custom of the jail was the direct cause of Donnie's suicide. The trial court granted summary judgment in favor of the defendants, finding that Sheriff Hamp was entitled to qualified immunity and that the plaintiffs failed to identify a single policy or custom of the County that directly caused Donnie's suicide. The plaintiffs appealed the trial court's decision to grant summary judgment in favor of the County.The Supreme Court of Mississippi affirmed the trial court's decision. The court found that the plaintiffs failed to present evidence to establish that the training provided to the jail employees demonstrated deliberate indifference by the County to the potential for constitutional injuries. The court also found that a single episode of an employee's failure to follow jail policy does not establish a pattern of constitutional violations amounting to the policy of the County. Therefore, the court concluded that the trial judge did not err by granting the County's motion for summary judgment. View "Clay v. Tunica County, Mississippi" on Justia Law

The case revolves around the dispute over whether the main roads within the Deerfield Estates subdivision in Newton County, Mississippi, are private or public. In 2001, the Newton County Board of Supervisors voted to accept the two main roads of the subdivision into the county road system. However, the roads were never added to the official county road registry. In 2020, the subdivision filed a complaint seeking a declaratory judgment that the roads are public and an injunction mandating the county to add them to the registry and perform repairs.The Newton County Chancery Court held that the roads had become public roads via express common law dedication and ordered that the roads be added to the county map and road register. The county appealed this decision, arguing that the subdivision's claims were barred by the doctrine of laches or the general three-year statute of limitations.The Supreme Court of Mississippi affirmed the lower court's decision. It held that the county's 2001 acceptance of the roads was effective and that the roads served public interest or convenience. The court also found that the county's failure to add the roads to the registry and the map in a timely manner did not negate the county's explicit acceptance of the dedication. Furthermore, the court ruled that the county could not invoke the doctrine of laches or the general three-year statute of limitations to bar the subdivision's request for a declaratory judgment that the roads are public roads. View "Newton County, Mississippi v. Deerfield Estates Subdivision Property Owners Association, LLC" on Justia Law