Justia Mississippi Supreme Court Opinion Summaries

In 2015, a Covington County jury found Howard Lindsey guilty of two counts of gratification of lust and two counts of sexual battery. On appeal, Lindsey argued that the jury’s verdict was contrary to the overwhelming weight of the evidence. Finding no issue with the verdict, the Supreme Court affirmed Lindsey’s convictions and sentences. View "Lindsey v. Mississippi" on Justia Law

The Mississippi Department of Corrections (MDOC) appeals the Sunflower County Circuit Court’s decision requiring it to develop a parole case plan for Robert Boyd. In 1986, Boyd was convicted of murder and two counts of aggravated assault. He was sentenced to life imprisonment for the murder, and to four years for each aggravated assault. In May 2001, MDOC released Boyd on parole. But eight years later, he absconded supervision and his parole was revoked. Boyd was released on parole a second time in September 2010, but again violated the terms of his parole and it was revoked in 2013. In July 2015, Boyd asked MDOC to implement a parole case plan for him in accordance with newly enacted Mississippi Code Section 47-7-3.1. When it refused, Boyd moved for judicial review at the Circuit Court, which found that the newly enacted code section could be applied retroactively to Boyd's sentence. Finding that the Circuit Court erred in its analysis of the new law, the Supreme Court reversed and remanded for judgment in favor of MDOC. View "Mississippi Dept. of Corrections v. Boyd" on Justia Law

Charles Allen, a parole-eligible inmate in the custody of the Mississippi Department of Corrections (MDOC), filed a request pursuant to the administrative review procedure (ARP) that MDOC develop a case plan for him. MDOC denied the request and, after exhausting his administrative remedies, Allen appealed to the Circuit Court of Sunflower County. The circuit court found that Allen was entitled to receive a case plan under an amendment to the Probation and Parole Law. MDOC appealed, arguing that the circuit court lacked jurisdiction over Allen's appeal because it was untimely, and, alternatively, that the Probation and Parole Law did not entitle Allen to receive a case plan. Because MDOC’s argument that the circuit court lacked jurisdiction over Allen’s action was not supported by the record, the Supreme Court did not consider it. The Supreme Court found that the Probation and Parole Law did not entitle Allen to a case plan. Therefore, the Court reversed the decision of the circuit court and rendered a decision in favor of MDOC. View "Mississippi Dept. of Corrections v. Allen" on Justia Law

The Mississippi Department of Corrections (MDOC) appealed the Sunflower County Circuit Court’s decision requiring it to develop a parole case plan for Jerry Bland. In 1982, Bland pleaded guilty to capital murder, burglary of a dwelling, and uttering a forgery. He was sentenced to life imprisonment for the capital murder, to ten years for the burglary, and to fifteen years for the forgery. Bland first was eligible for parole in October 1998, but he was denied. Since then, Bland had seven more parole hearings. After House Bill 585 went into effect in July 2014, Bland sought a parole case plan pursuant to newly enacted Mississippi Code Section 47-7-3.1. On July 1, 2015, Bland filed his "first step" with MDOC’s Administrative Remedy Program (ARP). In response, MDOC said that House Bill 585 was not retroactive and that it applied only to those offenders sentenced on or after July 1, 2014. Bland then filed a motion for judicial review with the Circuit Court, and the circuit judge reversed MDOC’s decision, finding that Section 47-7-3.1 applied retroactively to offenders sentenced before July 1, 2014. MDOC appealed. Because the Supreme Court found that section 47-7-3.1 did not clearly and unequivocally express an intention for retroactive applicability, the Supreme Court reversed the Circuit Court's judgment. View "Mississippi Dept. of Corrections v. Bland" on Justia Law

Quindon Thomas, an employee of a contractor at Chevron’s petroleum refinery plant in Pascagoula, was injured on the job. Thomas accepted workers’ compensation benefits provided by Chevron for his injuries. Thomas then sued Chevron and one of its employees for the same injuries. Chevron asserted the exclusive-remedy defense under the Mississippi Workers’ Compensation Act and the circuit court granted summary judgment to Chevron. Thomas appealed, arguing the trial court erred in granting summary judgment. After review, the Mississippi Supreme Court found that Chevron was not a statutory employer of Thomas and therefore was not immune from tort liability. Accordingly, the Court reversed the trial court’s grant of summary judgment in favor of Chevron, reversed the trial court’s denial of Thomas’s cross-motion for summary judgment, and remanded for a trial on the merits. View "Thomas v. Chevron U.S.A., Inc." on Justia Law

Circuit Court granted summary judgment in favor of Graceland Care Center of Oxford, LLC; Graceland Management Company, Inc.; Lafayette LTC, Inc.; and Yalobusha General Hospital and Nursing Home (collectively, Graceland) in a case brought by Shirley Adams for injuries her mother allegedly sustained while in the defendants’ care. As the basis for granting summary judgment, the circuit court determined that Adams was judicially estopped from bringing her suit because Adams had failed to disclose the suit in her prior bankruptcy proceedings. Adams appealed, and the Court of Appeals, in a plurality opinion, reversed the circuit court’s decision to grant summary judgment and remanded the case to the circuit court to proceed with a trial on the merits. The Supreme Court granted certiorari review and held that the Court of Appeals misapplied the applicable standard of review and the law of judicial estoppel in the instant case. Therefore, the Court reversed the Court of Appeals’ judgment, and reinstated and affirmed the circuit court’s judgment. View "Adams v. Graceland Care Center of Oxford, LLC" on Justia Law

HansaWorld USA, Inc. (HansaWorld) registered a foreign judgment with a Mississippi circuit court against Kimberlee Davenport from an award ordered by a court in Florida on claims of conversion and extortion. Davenport, a former employee of HansaWorld, also maintained claims against HansaWorld in a separate action before a federal district court in Mississippi alleging several violations of state and federal law, including Title VII of the Civil Rights Act for sexual harassment and discrimination. HansaWorld sought to collect on its foreign judgment by petitioning the circuit court to sell Davenport’s Employment Action, so the circuit court entered a Writ of Execution. With the Employment Action set to be auctioned off by the Forrest County sheriff, Davenport filed an Emergency Motion to Quash Writ of Execution mere days before the scheduled sale. At a hearing on the motion, the circuit court granted Davenport’s motion to quash on the condition that she post a $100,000 bond by that afternoon, the day of the scheduled sheriff’s sale. Davenport failed to post the conditional bond, and as a result, the sheriff sold her Employment Action to the highest bidder, HansaWorld, for $1,000. Following sale of her Employment Action, Davenport appealed to the Supreme Court. Having determined that the circuit court’s order was a final, appealable judgment and that the Supreme Court has jurisdiction to hear the appeal, the Supreme Court concluded that Davenport waived her right to challenge the circuit court’s imposition of the bond on appeal because she failed to challenge the bond before the circuit court. View "Davenport v. Hansaworld, USA, Inc." on Justia Law

After a nearby ditch began to erode causing significant property damage and mold-related health issues, Plaintiffs John and Patsy O’Callaghan filed an inverse condemnation action under the Takings Clause of the Mississippi Constitution, requesting that the City of Tupelo compensate the couple for both personal injuries and significant property loss. The City presented an interlocutory appeal challenging the County Court’s order denying its motion for summary judgment on the matter. Finding that personal injuries were not recoverable in a claim under the Takings Clause and that the three-year limitations period under Mississippi Code Section 15-1-49 was applicable to takings claims, the Supreme Court reversed the lower court’s ruling, rendering a decision for the City. View "City of Tupelo v. O'Callaghan" on Justia Law

Justin Crockett pled guilty in Panola County Justice Court to headlighting a deer. Crockett appealed his conviction to the Circuit Court of the First Judicial District of Panola County. After a bench trial de novo, that court found Crockett guilty. Crockett then appealed to the Mississippi Supreme Court, arguing solely that there was insufficient evidence to support the conviction. Finding sufficient evidence in the record to sustain Crockett’s conviction, the Supreme Court affirmed. View "Crockett v. Mississippi" on Justia Law

On the morning of his client’s trial, defense attorney A. Randall Harris tried to withdraw as counsel. When the judge declined his request, Harris told the judge he was “wrong” for doing so, and he “was not going to participate” in the trial. Harris’s refusal to abide by the court’s order forced a continuance. And the judge held him in direct criminal contempt. Harris appealed, but the Supreme Court affirmed the judgment finding Harris guilty of direct criminal contempt and ordering Harris to pay a $100 fine and $1,200 for the cost of the jury venire. View "Harris v. Mississippi" on Justia Law