Justia Mississippi Supreme Court Opinion Summaries

Quality Choice Correctional Healthcare entered a contract with Hinds County, Mississippi to provide comprehensive medical care to inmates. Delorise Rollins was hired by Quality Choice as a nurse at the Hinds County Detention Center in Raymond and was injured in the course of her duties. At that time, Quality Choice did not carry workers’ compensation coverage. As a result, Rollins filed a petition to controvert with the Mississippi Workers’ Compensation Commission. The Commission found that the Hinds County Sheriff’s Department (HCSD) was not Rollins’s statutory employer and denied workers’ compensation benefits. Rollins then appealed, and the Court of Appeals affirmed the Commission’s decision. The Mississippi Supreme Court granted Rollins’s petition for writ of certiorari, and found that because the HCSD was not Rollins' statutory employer, workers’ compensation benefits were not available. The Court therefore affirmed decisions of the Court of Appeals and the Commission. View "Rollins v. Hinds County Sheriff's Department et al." on Justia Law

The jury in this case was presented with two options: find the tractor driver 100 percent liable for the motorcycle riders’ injuries or not liable at all. Neither party requested a comparative-negligence instruction. And none was given. The jury found the tractor driver liable, but only awarded the motorcycle riders a fraction of their uncontested damages. Both parties filed posttrial motions: the motorcycle riders sought more damages; the tractor driver requested a new trial. The trial court granted a new trial, agreeing with the tractor driver that the jury had rendered a “compromise verdict.” At the second trial, the jury found in favor of the tractor driver. The motorcycle riders appealed, arguing the trial court erred by granting a new trial following the first verdict. The Mississippi Supreme Court determined the trial court did not abuse its discretion: the record supported the trial judge’s finding the jury had reached a compromise verdict in the first trial. Therefore, the Court affirmed the trial court's judgment. View "Richards v. Wilson" on Justia Law

After suffering two work-related injuries, Sheree Cleveland settled her workers’ compensation claims with Advance Auto Parts and its workers’ compensation insurance carrier, Indemnity Insurance Company of North America. The Workers’ Compensation Commission approved the settlement. Approximately one month later, the Employer/Carrier filed a Form B-31 indicating the last payment had been made. More than a year after that, Cleveland filed a motion asserting that the Employer/Carrier had not paid all compensation due under the settlement and that two medical bills remained outstanding. The Commission found that, because a one-year statute of limitations had expired, it lacked jurisdiction to enforce its order approving the settlement agreement. Cleveland appealed, and the Court of Appeals reversed, questioning whether the one-year statute of limitations applied to the claim. But instead of answering that question, the Court of Appeals found that the Employer/Carrier had been estopped from asserting a statute of limitations defense because it had agreed to pay the outstanding bills and had represented to the administrative law judge that it would do so. Further, the Court of Appeals also found Cleveland's contact with the Employer/Carrier within the limitations period tolled the statute of limitations, if, in fact, it applied. The Mississippi Supreme Court affirmed, but for different reasons than the appellate court. The Supreme Court determined the statute of limitations did not apply to Cleveland's motion for enforcement of the settlement order, therefore, her motion was timely filed. View "Cleveland v. Advance Auto Parts" on Justia Law

James Williams suffered a severe brain injury from complications following cervical spine surgery. A lawsuit was brought against the hospital and the surgeon for medical malpractice, which included a claim for wrongful death after Williams died. Dr. Orhan Ilercil was ultimately found to be 15 percent responsible for Williams’s injuries and death, which amounted to a judgment against him for $205,800. Dr. Ilercil appealed, contending, among other things, that the trial court erred by refusing to give an intervening/superseding-cause instruction. To this, the Mississippi Supreme Court agreed, reversed judgment and remanded for a new trial. View "Ilercil v. Williams" on Justia Law

The Mississippi Supreme Court accepted this case on certiorari review from the Court of Appeals. Shaun Seals worked for the Pearl River Resort; he alleged he was terminated for reasons relating to a work-related injury. Donna Brolick, Pearl River Resort’s director of employment compliance, was called as a witness at the hearing before an administrative judge (AJ). Brolick testified that she was previously vice president of human resources at Pearl River Resort at the time Seals’s position was phased out and he was let go in January of 2013. Brolick further testified that in 2012 the resort changed its management. Multiple upper-level positions were eliminated or consolidated. Seals’s position as director of transportation was one of several positions that were eliminated. The Workers' Compensation Commission reversed the AJ’s order. The Commission found that Seals had reached maximum medical improvement on November 13, 2015, but failed to prove any permanent disability or loss of wage-earning capacity for two reasons. The Commission found that Seals was let go for unrelated economic reasons, noting his receipt of severance pay and other benefits as well as the testimony and evidence adduced by the Resort. Seals appealed the Commission's decision to the Court of Appeals. The appellate court held the Commission was correct in its assessment of the date of maximum medical improvement but that the Commission erred by finding Seals failed to prove any loss of wage-earning capacity. The Court of Appeals reversed and remanded the decision of the Commission and directed the Commission to calculate Seals’s loss of wage-earning capacity and to award corresponding compensation. The Resort petitioned the Supreme Court for a writ of certiorari, which was granted. The Supreme Court adopted "the well-reasoned analysis of the opinion concerning maximum medical improvement," but was "constrained to reverse the Court of Appeals’ majority regarding loss of wage-earning capacity. Sufficient evidence supported the Commission’s decision that Seals had not suffered loss of wage-earning capacity." The Commission's decision was reinstated in toto. View "Seals v. Pearl River Resort & Casino" on Justia Law

The wrongful-death beneficiares and estate of Carolyn Smith appealed a circuit court's grant of summary judgment in favor of the Hardy Wilson Memorial Hospital (now known as Copiah County Medical Center). The trial court found the Smiths failed to produce evidence sufficient to show Carolyn Smith's injuries or death was caused by any negligence of the Hospital's nursing staff. After review, the Mississippi Supreme Court concurred with the trial court and affirmed judgment. View "Smith v. Hardy Wilson Memorial Hospital" on Justia Law

Lula McLeod and her husband, John McLeod, appeal the circuit court’s dismissal of their medical-negligence case on grounds that it was filed outside of the limit in the applicable statute of limitations. The Mississippi Supreme Court found that because the record reflected the case was timely filed, the circuit court’s judgment should be reversed and the matter remanded for further proceedings. View "McLeod v. Millette" on Justia Law

After an automobile accident in 2015, Reericka Belk and Tracey Crayton filed suit against Victoria Morton in the Lee County Court. The case was tried by jury in September 2017, and the jury returned a unanimous verdict in favor of Morton. Belk and Crayton filed a motion for a new trial, claiming that the jury disregarded the instructions of the court and rendered a verdict contrary to the overwhelming weight of the evidence. The court granted the motion for a new trial. Morton petitioned the Mississippi Supreme Court for an interlocutory appeal. After review, the Supreme Court determined the jury was properly instructed on the law and was informed of all the relevant facts. The verdict returned by the jury was not against the overwhelming weight of the evidence. The Court found the trial judge abused his discretion by granting the motion for a new trial. Therefore, the Cout reversed the trial court’s order granting a new trial, and reinstated the trial court’s judgment entered on the jury’s verdict. View "Morton v. Belk" on Justia Law

Vernon Walters was injured in a work-related incident in October 2006; the vehicle he was driving was struck by an oncoming train. After receiving workers’ compensation benefits, he and his wife, Donyell Walters, filed a third-party claim against the company operating the train involved in the collision, Kansas City Southern Railway Company (KCSR). The Walterses hired the Parsons Law Firm to represent them in their suit, and Tadd Parsons took the case. The Walterses’ lawsuit against KCSR was ultimately dismissed with prejudice in September 2010 for, among other reasons, failure to prosecute, failure to comply with discovery obligations and fraud upon the court. Tadd never told the Walterses that their case had been dismissed and led them to believe their case was ongoing. Three years after the case had been dismissed, Tadd admitted he fabricated a settlement offer from KCSR in the amount of $104,000 and advised the Walterses to accept the offer, which they did. When eight months passed after Tadd informed the Walterses about the fabricated settlement, the Walterses demanded to meet with Jack Parsons, the other general partner at the Parsons Law Firm. Jack offered the Walterses $50,000 to settle any claims they may have had against Tadd based on his conduct in representing them in the KCSR lawsuit. The Walterses refused Jack’s offer and then filed a claim against Tadd, Jack and the Parsons Law Firm, alleging claims of fraud, defamation, negligent representation, negligent and intentional infliction of emotional distress and punitive damages. The trial court granted partial summary judgment for the Walterses on the matter of liability, finding that Tadd and the Parsons Law Firm were liable for fraud and intentional infliction of emotional distress. The court then held a jury trial on damages. The jury verdict awarded the Walterses $2,850,002 in compensatory damages, which exceeded what the Walterses had demanded in compensatory damages in their complaint and in their motion to set damages. Finding the jury’s verdict shocked the conscience, the court remitted the damages to $1,034,666.67 in a second amended final judgment. Parsons appealed to the Mississippi Supreme Court, and the Walterses cross-appealed. The Supreme Court determined the trial court did not abuse its discretion by excluding irrelevant evidence about the underlying KCSR lawsuit because the value of the lawsuit had no bearing on the damages the Walterses sustained due to Tadd Parsons’s and the Parsons Law Firm’s fraud and IIED. Further, the Court determined the remitted verdict’s award of damages was excessive and not supported by substantial evidence. The trial court was therefore affirmed in part, reversed in part, and the matter remanded for a new trial on damages. View "Parsons v. Walters" on Justia Law

Angela Jones alleged she sustained a compensable back injury while working as a registered nurse at Baptist Hospital. A Workers’ Compensation Commission administrative judge determined that Jones sustained a compensable work-related injury. Baptist appealed the administrative judge’s decision to the full Mississippi Workers’ Compensation Commission, and the Commission reversed, determining Jones did not sustain a compensable work-related injury. Jones appealed, and the Court of Appeals reversed the Commission's decision. Baptist then petitioned for the Mississippi Supreme Court's review. Finding the Commission's decision was supported by substantial evidence, the Supreme Court reversed the Court of Appeals and reinstated the Commission's decision. View "Jones v. Mississippi Baptist Health Systems Inc." on Justia Law