Justia Mississippi Supreme Court Opinion Summaries

Donald Smith was indicted for two counts of kidnapping, one count of armed carjacking, and one count of felony evading a police officer. His case was set for trial on November 13, 2008. On that date, Smith orally moved for a continuance and a psychiatric examination. Under Uniform Rule of Circuit and County Court Practice 9.06, a mental evaluation and competency hearing are mandatory if the trial court has a reasonable ground to believe the defendant is incompetent to stand trial. Before Smith entered a guilty plea, the trial court ordered a mental evaluation of Smith that never was performed. The record was silent as to the reason the trial court ordered the mental evaluation. The Supreme Court granted Smith’s petition for certiorari on his postconviction claim that the trial court had erred by accepting his guilty plea without a completed mental evaluation and competency hearing. Because a mental evaluation and hearing were required if the trial court ordered the mental evaluation to assess Smith’s competence to stand trial, the Court reversed and remanded for an evidentiary hearing on the issue of why the trial court ordered a mental evaluation. View "Smith v. Mississippi" on Justia Law

Jeremy Cage appealed his conviction for statutory rape, arguing that the trial court erred in excluding certain evidence and in denying his motion for a new trial. Cage also claimed that he was denied effective assistance of counsel. Finding no reversible error, the Supreme Court affirmed Cage’s conviction and sentence. View "Cage v. Mississippi" on Justia Law

On June 24, 2014, Thad Cochran, a Republican nominee for United States Senator, won the Republican primary runoff. His opponent, Chris McDaniel, filed an election contest with the State Republican Executive Committee (SREC) on August 4, 2014 – forty-one days after the election. The SREC declined to consider McDaniel’s complaint, and McDaniel appealed. The trial judge found that McDaniel did not meet the twenty-day deadline to file his election contest and dismissed the case. On appeal, McDaniel argued that no deadline existed to contest a primary election. Under the doctrine of stare decisis, the Supreme Court found that there indeed was a deadline, and McDaniel failed to file his election contest within twenty days. The dismissal was affirmed. View "McDaniel v. Cochran" on Justia Law

In this replevin action, a tenant sued his landlord and a towing company, alleging wrongful possession of several vehicles towed from the property he leased from the landlord. The County Court granted the defendants' motion for involuntary dismissal, and also found that the landlord's use of self-help was lawful. The Circuit Court affirmed. Finding that the plaintiff presented sufficient evidence to maintain the replevin action, the Court of Appeals reversed and remanded the replevin action for a trial de novo between the plaintiff and the towing company. It also found the landlord's use of self-help to be unlawful, and reversed and rendered that issue in favor of the plaintiff. Because the Supreme Court find that both the trial court and the Court of Appeals improperly addressed the issue of the landlord's use of self-help, it reversed the judgments and remanded the replevin action to the trial court for a trial de novo. View "Crowell v. Butts" 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

When Monsanto Company sued Mitchell Scruggs and his various agricultural entities for patent infringement in federal court, Scruggs made a demand on his commercial general liability insurer, Farmland Mutual Insurance Company. Farmland denied coverage based on Scruggs's alleged intentional conduct. Scruggs then sued Farmland, Greg Bost (the insurance agent), and Nowell Insurance Agency in state court. The circuit court ultimately granted summary judgment for Bost and Nowell. Scruggs appealed to the Mississippi Supreme Court, arguing, among other things, that Bost and Nowell negligently failed to advise him that he needed to purchase patent infringement insurance. Because the Supreme Court found Scruggs's conduct was uninsurable as a matter of law, it affirmed. View "Scruggs v. Bost" 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

The Circuit Court granted summary judgment in favor of Arch Specialty Insurance Company, finding that Arch's general liability policy did not provide coverage for the claims asserted by the wrongful death beneficiaries of William Gray. The Grays' claimed negligent hiring, negligent training, and failure to implement appropriate triage protocols arose from the performance of or failure to perform medical services, against Arch's insured. The Grays appealed. Finding no error, the Supreme Court affirmed. View "Gray v. Arch Specialty Insurance Company" on Justia Law

EDW Investments, LLC, obtained a judgment against Techtronics, Inc. in 2007. In 2011, EDW sued Michelle Barnett ("Michelle"), the wife of Techtronics' president, Kevin Barnett ("Kevin"); Spectrum Wireless, LLC; MWB Holdings, LLC; and L4, LLC, claiming that: (1) these limited liability companies "are alter ego entities created solely to conceal the assets and income of Techtronics, Inc. from EDW" and that "Michelle Barnett knowingly participated in these efforts"; (2) "[t]he assets and income of Techtronics, Inc. were fraudulently conveyed to Michelle Barnett and the shell entities to avoid paying EDW"; and (3) "[t]he actions of the [Defendants] were grossly negligent, willful and/or intentional and constitute violation of common law duties under Mississippi law." The trial judge granted Defendants' motion to dismiss, and EDW appealed. Finding no error, the Supreme Court affirmed the decision to dismiss. View "EDW Investments, LLC v. Barnett" on Justia Law

Following the May 7, 2013, Democratic primary for the Ward 5 seat on the Greenwood City Council, the Greenwood Municipal Democratic Executive Committee certified Dorothy Ann Glenn as the winner and thus the Democratic nominee for the Ward 5 seat on the City Council. Runner-up Andrew Powell challenged the election results, contending that Glenn was not a resident of Ward 5 at the time of the election and that she consequently was ineligible to run for that office. Powell sought a special primary runoff election, without Glenn's name on the ballot. The Circuit Court of Leflore County, Special Election Tribunal, found that Glenn was not a resident of Ward 5, held that she was not qualified to hold the position of Greenwood City Council Member for Ward 5, set aside the results of the election, and ordered a special primary runoff election without Glenn's name on the ballot. The Supreme Court affirmed in part and reversed in part and vacated the order of the circuit court for a special primary runoff election. View "Glenn v. Powell" on Justia Law