Justia Mississippi Supreme Court Opinion Summaries

The issue before the Supreme Court was whether the Mississippi Department of Health erred by denying the certificate-of-need (CON) application of St. Dominic-Jackson Memorial Hospital. In its application, St. Dominic sought to relocate seventy-one general acute-care beds from its Jackson location to a new facility in planned to build in Madison County. The Department found that St. Dominic's proposed project was actually a new hospital and not a relocation. Because St. Dominic did not meet the need criteria for a new hospital, the Department denied the request. The Madison County Chancery Court affirmed that decision. St. Dominic raised four issues on appeal. Taking each in turn, the Supreme Court concluded that the Department did not err by finding St. Dominic's project was actually a new hospital. Because St. Dominic could not meet the need criteria for a new hospital, the Department did not err by denying the CON application, and that the chancery court did not err by affirming that decision. View "St. Dominic-Jackson Memorial Hospital v. Mississippi State Department of Health" on Justia Law

Property owners (collectively, "the Rhalys") sued the City of Jackson for flooding to their properties allegedly caused by the City's failure to maintain a ditch. The Circuit Court of Hinds County struck the City's answer due to "gross indifference to its discovery obligations," based upon its failure to produce the "Streets, Bridges, and Drainage Division of the Public Works Department Operations and Maintenance Policy Manual." The court entered a default judgment in favor of the Rhalys. The Court of Appeals affirmed. The City appealed. Upon review, the Supreme Court concluded that the City indeed exhibited "gross indifference to its discovery obligations" and affirmed both the circuit court and the Court of Appeals. View "City of Jackson v. Rhaly" on Justia Law

After an insolvent employer's insurance company also became insolvent, the Mississippi Workers' Compensation Self-Insurers Guaranty Association (SIGA) made workers' compensation payments to an injured worker. SIGA sued the Mississippi Insurance Guaranty Association (MIGA) for reimbursement of those payments, and the trial court ordered reimbursement. The issue came before the Supreme Court who, after consideration, concluded that SIGA's claim against MIGA did not fall within the statutory definition of a "covered claim," and reversed the trial court’s reimbursement decision. View "Miss. Insurance Guaranty Ass'n v. Miss. Workers' Comp. Indv. Self-insurer Guaranty Ass'n" on Justia Law

In 2002, Dung Thi Hoang Nguyen stopped behind Karen Thompson at a red light. In reaching for her purse, her foot slipped off the brake and her car bumped into Thompson's. Neither car was damaged. The two exchanged insurance information without calling the police. But after Thompson arrived at her parents' home, her father told her to get a police report for her insurance provider, so Thompson called Nguyen, who agreed to meet her at the police station that night. A few days later, Thompson visited her physician complaining of neck pain. An MRI of Thompson’s spine revealed a preexisting degenerative-disc disease associated with disc bulges. And despite ongoing therapy, Thompson continued to complain of headaches, insomnia, depression, and neck pain until, in 2004, she was referred to a neurosurgeon, who performed surgery in 2005, Thompson to treat her abnormal discs. Thompson filed suit against Nguyen, seeking $234,316.49 in compensation. Nguyen admitted liability but contested that the accident had caused Thompson that much damage. A jury awarded Thompson $9,131– the exact amount of her physical therapy bills, but she filed a motion for additur or a new trial on damages alone, which the circuit court denied. Thompson appealed, and the Court of Appeals reversed and remanded for a trial on damages. The jury awarded Thompson less than the amount requested. Thompson appealed the jury’s second award. Because causation was central to Thompson's argument for the new damages award, the Supreme Court found it a question of fact for the jury, and affirmed its award. View "Thompson v. Nguyen" on Justia Law

The Supreme Court granted certiorari in this case to address whether in a driving-under-the-influence trial, the admission of intoxilyzer calibration records, in lieu of the live testimony of the person who calibrated the Clause contained in the Sixth Amendment to the United States Constitution. Finding no constitutional violation, the Court affirmed the judgments of the Court of Appeals and the Madison County Circuit Court: "[the are nontestimonial in nature. Therefore, [Defendant's] Confrontation-Clause rights were not violated." View "Matthies v. Mississippi" on Justia Law

In 2006, Petitioner Chander Khurana was audited by the Mississippi State Department of Revenue (MSDR) and assessed taxes. Petitioner appealed the assessments to the Board of Review and eventually the full State Tax Commission, both of which affirmed the assessment. In 2007, Petitioner filed his appeal of the assessments to the Chancery Court; however he did not pay the taxes or post a bond at the time he filed his petition as required by statute. MSDR filed a motion for summary judgment and dismissal, arguing Petitioner failed to perfect his appeal. The chancellor denied the motion and ultimately affirmed the assessments. Petitioner appealed to the Supreme Court claiming the full Commission and chancery court acted arbitrarily and capriciously. MSDR cross-appealed, claiming the chancellor erred in denying its motion for summary judgment and dismissal. Upon review, the Supreme Court concluded Petitioner failed to comply with the statutory requirements of paying the tax or bond. Therefore, the chancery court did not have appellate jurisdiction over Petitioner's appeal, and should have granted MSDR's motion for summary judgment and dismissal. The Court reversed the judgment of the chancery court and rendered judgment for the Mississippi Department of Revenue. Because the chancery court should not have reached the merits of the case, the chancery court's order affirming the assessments was vacated. The order of the Commission remained in effect. View "Khurana v. Mississippi Dept. of Revenue" on Justia Law

The issue before the Supreme Court concerned a custody dispute on interlocutory appeal. The Lauderdale County Youth Court denied Theresa and Ralph Anderson's Motion to Transfer Jurisdiction to the Chancery Court of Neshoba County in the matter involving neglected and abused minors. Aggrieved, the Andersons appealed, arguing that the youth court erred in retaining jurisdiction over the matter because chancery courts have jurisdiction over custody matters, and because the youth court previously terminated its jurisdiction over the minors involved. Upon review, the Supreme Court found no error and affirmed the order of the youth court denying the Motion to Transfer Jurisdiction. View "In the Interest of M.I. and T.I." on Justia Law

In 2006, Defendant Ladennis Graham pled guilty to simple possession of approximately twelve grams of cocaine. The circuit court sentenced Defendant to serve sixteen years in the Mississippi Department of Corrections (MDOC) with fifteen years to be suspended upon the successful completion of twelve months of house arrest, four years of supervised post-release supervision and completion of a community service program. While Defendant was on house arrest, MDOC determined he violated the conditions of his suspended sentence when he was arrested at his brother's house during the execution of a search warrant, which turned up a number of guns and narcotics. Defendant was required to serve the remainder of his sixteen-year sentence as an inmate. Defendant then filed a motion for post-conviction relief (PCR) which was dismissed for lack of subject matter jurisdiction. On appeal, the Court of Appeals found that Defendant's sentence was illegally vague and indeterminate, and remanded the case for revocation of Defendant's sentence if the circuit court or State chose to initiate such a proceeding. Upon review, the Supreme Court concluded the Court of Appeals was correct in reversing the circuit court’s ruling that it did not have proper jurisdiction to hear Defendant's motion for post-conviction collateral relief. However, it was improper for the Court of Appeals to rule on the merits of Defendant's motion without the circuit court doing so first, as the circuit-court had exclusive, original jurisdiction. The judgment of the Court of Appeals was vacated; the circuit court judgment was reversed, and the case was remanded to the circuit court for further proceedings. View "Graham v. Mississippi" on Justia Law

The Pascagoula School District (which contains a Chevron crude oil refinery and a Gulf liquified natural gas terminal) brought suit, seeking a declaration that a new law that mandated that revenue the District collected from ad valorem taxes levied on liquified natural gas terminals and crude oil refineries be distributed to all school districts in the county where the terminals and refineries were located was unconstitutional and requesting injunctive relief. All parties filed for summary judgment. After a hearing, the trial judge ruled that the law was constitutional, and the plaintiffs appealed that decision. Because the Supreme Court found the contested statute violated the constitutional mandate that a school district's taxes be used to maintain "its schools," it reversed and remanded the case for further proceedings. View "Pascagoula School District v. Tucker" on Justia Law

Precious Martin and Associates, PLLC (Martin) contracted with T. Jackson Lyons & Associates, P.A. (Lyons) to handle appeal work on several of Martin's cases. After Martin stopped paying for the work, Lyons filed a complaint in the County Court alleging breach of contract and claiming $14,543.19 owed on open account. The county court awarded Lyons $14,543.19 in damages and $4,847.73 in attorney's fees. Martin appealed to the Circuit Court claiming that the trial court erred in awarding attorney's fees. The circuit court reversed the county court judgment on the basis that the agreement between the law firms was an oral contract, not an open account, such that attorney's fees should not have been awarded. Aggrieved, Lyons appealed to the Supreme Court. Upon review, the Court found that the circuit court's reversal of the award of attorney's fees was not supported by the evidence. The county court's award of attorney’s fees was supported by the credible evidence and was not an abuse of discretion. The judgment of the Circuit Court was reversed, and the judgment for attorney's fees entered by the County Court was reinstated and affirmed. View "T. Jackson Lyons & Associates, P. A. v. Precious T. Martin, Sr. & Associates, PLLC" on Justia Law