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

Patricia Wright was employed by the Public Service Commission of Yazoo City (PSC) from August 2014 until November 2018, when she was terminated for allegedly falsifying documentation regarding reconnecting a customer for non-payment. Wright appealed her termination to the PSC Board, which upheld the decision. Subsequently, Wright filed a lawsuit against the PSC and its general manager, Richie Moore, claiming her termination was in retaliation for refusing to participate in illegal activities. She sought lost wages, benefits, compensatory damages, punitive damages, and costs.The Yazoo County Circuit Court denied the PSC's motion for summary judgment, finding that there was a genuine issue of material fact regarding the reason for Wright's termination. The trial judge noted that the question of whether Wright understood what falsifying documents entailed and whether she was asked to do so was a matter for the jury to decide. The PSC then filed a petition for interlocutory appeal, arguing that Wright failed to identify any illegal activity by her supervisor that could lead to criminal penalties.The Supreme Court of Mississippi reviewed the case and reversed the trial court's denial of summary judgment. The Court held that Wright failed to provide sufficient evidence that her supervisor's actions constituted illegal activities warranting criminal penalties. Wright's deposition revealed that she did not refuse to participate in any specific illegal act as required under the public policy exception to the employment at will doctrine. Consequently, the Court rendered judgment in favor of the PSC, concluding that Wright did not meet her burden of showing a genuine issue of material fact regarding her wrongful termination claim. View "Public Service Commission of Yazoo City v. Wright" on Justia Law

The case revolves around a dispute between American Compensation Insurance Company (ACIC) and Hector Ruiz, who operates Los Primoz Construction. Ruiz's employee, Raul Aparacio, suffered severe injuries after falling more than fifteen feet at a worksite. ACIC, which provided workers' compensation insurance for Ruiz's company, began paying benefits to Aparacio. However, when the payouts exceeded a quarter of a million dollars, ACIC sought to retroactively void the policy, alleging that Ruiz had materially misrepresented in his application that his company did not perform work more than fifteen feet above ground.The insurer filed for a declaratory judgment in federal court, but the federal district judge dismissed the insurer's lawsuit, concluding that Mississippi’s workers' compensation law does not permit an insurer to rescind a workers' compensation policy. The insurer appealed to the Fifth Circuit, which certified the question to the Supreme Court of Mississippi.The Supreme Court of Mississippi held that the Mississippi Workers’ Compensation Act (MWCA) does not allow insurers to void a workers' compensation policy based on an employer's material misrepresentation. The court reasoned that the MWCA makes no provision for an insurer to void a workers' compensation policy based on a material misrepresentation and exists to ensure injured workers are compensated. The court concluded that allowing rescission would go against the purpose of the MWCA. View "American Compensation Insurance Company v. Ruiz" 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

Heather Walters, a Direct Support Professional at Brandi’s Hope Community Services, a long-term care facility for people with intellectual and developmental disabilities, noticed that a resident had been physically abused. She attempted to report the incident to her supervisors but received no response. Walters then took a photograph of the resident's injuries and shared it with a former coworker. After an internal investigation, Walters was fired for violating company policy and HIPAA regulations by taking and sharing the photograph. Walters filed a lawsuit against Brandi’s Hope and its CEO, Danny Cowart, for retaliatory discharge and malicious interference with employment.The County Court of Lee County found in favor of Walters, awarding her $100,000 in damages. The defendants appealed to the Lee County Circuit Court, which affirmed the lower court's decision. The defendants then appealed to the Court of Appeals, which reversed the lower courts' decisions, finding that the Mississippi Vulnerable Persons Act and the public policy exception established in McArn v. Allied Bruce-Terminix Co., Inc. were in conflict.The Supreme Court of Mississippi reversed the Court of Appeals' decision, finding no conflict between the Mississippi Vulnerable Persons Act and the public policy exception established in McArn. The court held that Walters was eligible to claim wrongful termination under McArn, as she was fired for reporting illegal activity. The court affirmed the jury's verdict that Brandi’s Hope terminated Walters because she reported the abuse. The case was remanded to the County Court of Lee County for further proceedings. The Court of Appeals' decision to render judgment in favor of Cowart on the malicious-interference-with-employment claim was not reviewed and thus stands. View "Brandi's Hope Community Services, LLC v. Walters" on Justia Law

In the case before the Supreme Court of Mississippi, Vince Hardaway brought an action against his employer, Howard Industries, Inc., claiming bad faith denial of his workers’ compensation benefits for temporary partial disability due to carpal tunnel syndrome. Howard Industries had contracted CorVel Enterprise, a third-party claims administrator, to manage workers’ compensation claims. The trial court granted summary judgment in favor of Howard Industries, finding that the company's conduct did not constitute gross negligence or an independent tort.On appeal, the Supreme Court of Mississippi affirmed the trial court's decision. The court found that under Mississippi Code Section 71-3-125(1), Howard Industries was permitted to delegate its duty to administer employee workers’ compensation claims to CorVel. The Court also determined that Hardaway failed to provide sufficient evidence that Howard Industries acted with actual malice or gross negligence in denying his benefits. Therefore, his claims did not survive summary judgment. The court held that any failure to pay benefits by Howard Industries under these circumstances did not amount to gross negligence. View "Hardaway v. Howard Industries, Inc." on Justia Law

Jackson Federation of Teachers (JFT) filed a complaint against the Jackson Public School District (JPS), alleging alleged that certain JPS policies violated the free speech rights of its employees. The trial court: (1) denied JPS’s motion to dismiss for lack of standing; (2) denied JPS’s motion to dismiss for mootness; (3) found that JPS’s three policies were in violation of article 3, section 11, and article 3, section 13, of the Mississippi Constitution; and (4) issued a permanent injunction enjoining JPS from enforcing the policies. JPS timely appealed. Because JFT failed to establish standing, the Mississippi Supreme Court reversed the trial court’s decision and rendered judgment in favor of JPS. View "Jackson Public School District v. Jackson Federation of Teachers, et al." on Justia Law

The Louisiana Workers’ Compensation Commission imposed a $1,000 sanction against an employer’s attorney for submitting misleading documentation to an Administrative Judge (AJ). The Court of Appeals affirmed the sanction and the Commission’s award of permanent disability benefits to the employee. On certiorari review, the Luisiana Supreme Court agreed with the Court of Appeals that the sanction should have been affirmed. View "Howard Industries, Inc. v. Hayes" on Justia Law

A Mississippi circuit court granted law firm Campbell DeLong, LLP, a declaratory judgment against a former partner of the firm, Britt Virden, who had alleged breach of contract, among other claims. Virden appealed, and the Court of Appeals affirmed. On certiorari review, the Supreme Court found that Virden’s prewithdrawal claims were not precluded by a signed agreement, which only came into operation in the event of death, termination, withdrawal, or retirement of a partner. The Supreme Court therefore reversed the appellate and circuit court judgments and remanded the case for the circuit court to allow Virden an opportunity to maintain an action against his former firm for breach of an implied contract regarding partner compensation. View "Virden v. Campbell Delong, LLP, et al." on Justia Law

Defendant Alex Herrgott, was driving a four-seat Polaris all-terrain vehicle at night down a gravel road when he “overcorrected” trying to avoid a pothole. The ATV overturned, and Joseph MacNabb, a passenger, was severely injured. Since MacNabb was a state employee in the course and scope of his employment, he received workers’ compensation benefits from the Mississippi State Agencies Self-Insured Workers’ Compensation Trust. The Trust later initiated this litigation in an attempt to recover more than $300,000 in benefits paid for MacNabb’s injury. The circuit court ultimately granted summary judgment to Herrgott because the Trust’s Mississippi Rule of Civil Procedure 30(b)(6) representative could not articulate a legal theory entitling it to recover. The Mississippi Supreme Court found there was sufficient evidence of Herrgott’s negligence for the case to go to trial, and the deposition testimony of a lay witness should not have bound the Trust as to which legal theories it could pursue. The Supreme Court therefore reversed the summary judgment and remanded the case for trial. View "Mississippi State Agencies Self-Insured Workers' Compensation Trust v. Herrgott" on Justia Law