Justia Mississippi Supreme Court Opinion Summaries
Tyler v. Automotive Finance Company, Inc.
The trial court granted summary judgment in favor of plaintiff Automotive Finance Company, after defendant Paul Tyler failed to respond in a timely manner to a request for admissions. Defendant's argument on appeal was that he was not properly served with either the request for admissions or the following motion for summary judgment. The trial court entered an order deeming the unanswered request admitted. Based upon the evidence contained within the admissions, the court also granted Automotive Finance's motion for summary judgment. Well after the trial court entered a final judgment, Defendant filed a motion to amend his admissions, which the trial court denied. Defendant appealed both the order denying reconsideration of summary judgment and the order denying his post-finaljudgment motion to amend the admissions. Finding no error on the part of the trial court, the Supreme Court affirmed.
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Constitutional Law, Mississippi Supreme Court
Burdette v. Mississippi
Derrick Burdette was indicted and tried for the murder of Herman Smith. The jury acquitted him of murder but found him guilty of the lesser offense of manslaughter. Burdette was sentenced to a twenty-year term in the custody of the Mississippi Department of Corrections (MDOC), to run consecutively with a sentence he already was serving for an unrelated offense. On appeal, Burdette argued: (1) that the jury verdict was against the overwhelming weight of the evidence, and (2) that his Confrontation Clause rights were violated at trial. Upon review, the Supreme Court found that the jury verdict was not against the weight of the evidence. While the Court found error amounting to the violation of Burdette's right to confront the witnesses against him, the error did not result in a manifest miscarriage of justice. Accordingly, the Court affirmed the judgment of the circuit court. View "Burdette v. Mississippi" on Justia Law
Alston v. Pope
Plaintiffs Shirley and Robert Alston filed suit against Defendants Justin Pope and T.K. Stanley, Inc. seeking damages they claimed resulted from a motor-vehicle accident in Tuscaloosa, Alabama. The circuit court dismissed the case on grounds of forum non conveniens. The Alstons then filed suit in Alabama. The suit was dismissed because Alabama's statute of limitations for the claim had expired. The Alstons thereafter filed a motion for relief from judgment, under Rule 60(b) of the Mississippi Rules of Civil Procedure at the circuit court, claiming the circuit court's previous dismissal was void because Defendants had failed to file a written stipulation with the court, waiving the right to assert a statute-of-limitations defense. The circuit court denied the Alstons' motion and the Alstons appealed. The Court of Appeals reversed and remanded the matter for an adjudication on the merits after finding the circuit court abused its discretion by denying the Alstons' Rule 60(b) motion. Defendants appealed to the Supreme Court. After its review, the high court found that the Court of Appeals erred in reversing the circuit court's decision to deny the Alstons' Rule 60(b) motion, Accordingly, the Court reversed the Court of Appeals' decision and reinstated and affirmed the circuit court's judgment denying the Alstons' Rule 60(b) motion.
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Williams v. Mississippi
Defendant Tyrell Williams was convicted of sexual battery and sentenced to twenty years in the custody of the Mississippi Department of Corrections (MDOC). On appeal, he argued that he did not knowingly waive his constitutional rights, and the trial court therefore erred in denying his motion to suppress his inculpatory statement. Because the trial judge applied an incorrect legal standard at the suppression hearing, the Supreme Court reversed and remanded the case for a new suppression hearing and a new trial. View "Williams v. Mississippi" on Justia Law
Virginia College, LLC v. Blackmon
The trial court denied defendant Virginia College's motion to compel arbitration. Because the plaintiffs failed to allege sufficient facts to support a claim that they were fraudulently induced to agree to the arbitration provision, the Supreme Court reversed and remanded the case for further proceedings. View "Virginia College, LLC v. Blackmon" on Justia Law
In The Matter of the Enlarging, Extending and Defining the Corporate Limits and Boundaries of the City of Biloxi
In a case consolidating the competing annexation petitions of Biloxi and D’Iberville, the chancellor ultimately awarded each city a reduced area from that requested, determining that it was unreasonable for either city to annex the entire area requested, and then determining that it was reasonable to award each city a smaller, reduced area. Both cities appeaedl this decision, and Biloxi raised jurisdictional issues for the first time on appeal. Because Biloxi raised personal jurisdiction on behalf of third parties, and because Biloxi failed to raise this issue at the trial-court level, the Supreme Court found that Biloxi not only lacked standing to raise this issue, it also waived it. Further, because the chancellor’s decision awarding each city a reduced area was reasonable and supported by substantial evidence, the Supreme Court affirmed the annexations as modified by the chancellor. View "In The Matter of the Enlarging, Extending and Defining the Corporate Limits and Boundaries of the City of Biloxi" on Justia Law
GGNSC Batesville, LLC v. Johnson
In a wrongful death action against a nursing home, the nursing home moved to compel arbitration, arguing that the nursing home resident was the third-party beneficiary to the admission and arbitration agreements signed by his sister. The trial court denied the motion, finding that no valid contract was signed by someone with the legal authority to do so, and the nursing home appealed. Because the resident's sister lacked the authority to contract for him, and thus no valid contract existed, the Supreme Court affirmed the trial court’s denial of the motion to compel arbitration. View "GGNSC Batesville, LLC v. Johnson" on Justia Law
Veazy v. Mississippi
Rico Veazy and Brandon Mosley were convicted of armed robbery and were sentenced to eight and ten years, respectively, in the custody of the Mississippi Department of Corrections after being tried together in circuit court. The robbery involved a vehicle belonging to Veazy but undergoing repairs by mechanic Jimmy Smith, who testified that the vehicle was taken from his repair shop by gunpoint. Finding no merit in any of the defendants' issues raised on appeal, the Supreme Court affirmed the circuit court's judgment. View "Veazy v. Mississippi" on Justia Law
Mississippi Comm’n on Judicial Perf. v. Smith
The Mississippi Commission on Judicial Performance recommended that Mendenhall municipal court judge Bruce B. Smith be publicly reprimanded, suspended from office for thirty days without pay, and pay costs for: (1) failing to properly adjudicate criminal matters assigned to him; (2) engaging in ticket-fixing; and, (3) dismissing criminal charges against multiple defendants in exchange for simultaneous payments to a "drug fund" established and maintained by the Mendenhall police chief. The Commission found that Judge Smith's conduct constituted willful misconduct in office and conduct prejudicial to the administration of justice which brought the judicial office into disrepute under Section 177A of the Mississippi Constitution of 1890. Specifically, the Commission found by clear and convincing evidence that Judge Smith violated Canons 1, 2A, 3B(1), 3B(2), and 3B(8) of the Code of Judicial Conduct. Upon review, the Supreme Court concurred with the Commission’s findings and adopted its proposed discipline.
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Mississippi State & School Employees’ Life and Health Plan v. KCC, Inc.
KCC, Inc., d/b/a Vital Care of Meridian (Vital Care) filed a complaint against the Mississippi State and School Employees' Life and Health Plan ("the Plan") and the Plan’s pharmacy benefits manager, Catalyst Rx, alleging that the Plan and Catalyst had violated Mississippi Code Section 83-9-6 by designating Walgreens Pharmacy as the sole provider of specialty pharmacy services. Later, Vital Care moved for partial summary judgment on the question of whether Section 83-9-6 applied to the Plan. The Chancery Court granted Vital Care’s motion for partial summary judgment, and the Plan and Catalyst appealed. Upon review of the applicable statute, the Supreme Court found that Section 83-9-6 applied to the Plan because it applies to "all health benefit plans providing pharmaceutical services benefits, including prescription drugs, to any resident of Mississippi" and was not ambiguous. View "Mississippi State & School Employees' Life and Health Plan v. KCC, Inc." on Justia Law