Justia Mississippi Supreme Court Opinion Summaries

J.C. and Betty Lockhart owned a life estate in an undivided one-fourth interest in 160 acres in Monroe County, Mississippi. After the death of J.C., Betty Lockhart filed a complaint to partition by public sale the land that she shared with her in-laws, Bolin and Orene Hamilton. The Hamiltons also owned a life estate in the same property, and they maintained the property as their homestead. Additionally, Lockhart sued Richard and Peggy Collins, who have a future interest in the property as remaindermen. The trial court dismissed Lockhart's petition, and Lockhart appealed. Because Lockhart failed to meet the statutory requisites for a partition sale, the Supreme Court affirmed the chancellor's ruling. View "Lockhart v. Collins" on Justia Law

The issue on appeal to the Supreme Court was whether the circuit court erred in granting summary judgment for the Mississippi Insurance Guaranty Association (MIGA), and in denying a cross-motion for summary judgment for nursing homes and nursing-home residents. The circuit court found that MIGA was entitled to a credit, which would reduce the amount MIGA must pay to indemnify nursing-home owners and operators for damage claims of two nursing-home residents that were allegedly caused by a series of negligent acts and omissions over the course of many years. Upon review, the Court found "the factual and legal predicates necessary to formulate an opinion on coverage issues are lacking, which would preclude any court from rendering a valid ruling on coverage." The Court reversed the circuit court's judgment that granted MIGA's motion for summary judgment and that denied the cross-motions for summary judgment. View "Louisiana Extended Care Centers, Inc. v. Mississippi Insurance Guaranty Ass'n" on Justia Law

In July 2006, Respondent Paul Cook's workers' compensation claim was dismissed for failure to file a properly completed prehearing statement. In December 2006, his "Motion for an Order Re-Instating Claim" was denied for failing to "attach a properly completed prehearing statement . . . ." In August 2008, Respondent's "Amended Motion to Reinstate" was dismissed as barred under a one-year statute of limitations. The full Commission affirmed the dismissal, as did the circuit court and a unanimous Mississippi Court of Appeals. The Supreme Court granted Respondent's petition for certiorari and affirmed: "Cook's claim was properly dismissed. To hold otherwise would eviscerate the Commission's rules and rulings of their statutorily intended effect, since '[a] rule which is not enforced is no rule at all.'" View "Cook v. The Home Depot" on Justia Law

Defendant Arturo Aquirre Moreno filed a motion to proceed in the trial court with his third petition for post-conviction relief. The Supreme Court granted him leave to proceed solely on the issue of ineffective assistance of counsel, and the trial court held a hearing only on that issue. The Court concluded that it improperly exercised authority to consider Defendant's motion and thus should not have remanded for an evidentiary hearing. Notwithstanding its own error, the Court affirmed the trial court's denial of relief to Defendant on his ineffective assistance of counsel claim: "[t]o reverse based on the procedural error would be futile, as the result is the same: the trial court was the first (and therefore proper court) to pass on the merits of that claim." Further complicating the issues in this case, Defendant also raised double jeopardy and venue claims for the first time on appeal. The Court of Appeals addressed all of Defendant's claims and denied him relief. The Supreme Court found that the appellate court erroneously considered Defendant's double jeopardy and venue claims. The Supreme Court declined review of Defendant's claims. View "Moreno v. Mississippi" on Justia Law

In 2008, Rehab Solutions, PLLC (Rehab) received notice of tax liens assessed against its property. Thereafter, Chad Willis and Renee Willis (collectively, the Owners) employed the Nail McKinney Accounting firm to assess the financial viability of their business. As a result, numerous financial shortcomings of Rehab’s in-house accountant became apparent. When the inspection of Rehab’s finances began, the accountant left work and did not return. Rehab eventually sued the accountant in tort and in contract, seeking the return of one-half of his wages while employed by Rehab, as well as punitive damages. The jury returned a verdict in favor of Rehab and awarded Rehab $133,543.17 in compensatory damages and $50,000 in punitive damages. The accountant appealed the jury’s award, asserting that it was not supported by the evidence and that unjust enrichment was not the proper measure of damages. Additionally, the accountant contended that the trial court erred in finding that Rehab’s claims were not barred by the statute of limitations and for submitting the issue of punitive damages to the jury. After a thorough review of the record, the Supreme Court determined that there was not a viable cause of action against the accountant in this matter. Accordingly, the Court reversed the trial court and remanded the case for further proceedings. View "Willis v. Rehab Solutions, PLLC" on Justia Law

In 2009, Plaintiff Charles McGraw filed a personal-injury action against four sand suppliers: Clark Sand Company, Inc.; Mississippi Valley Silica Co. Inc.; Precision Packaging, Inc.; and Custom Aggregates and Grinding, Inc. Plaintiff alleged the four defendants’ sand caused his lung disease. On the day of the trial, after the jury heard the parties’ opening statements, the court recessed, and the parties reached a settlement agreement. A few months later, Plaintiff filed a motion for leave to amend his complaint to add his wife as a plaintiff and to add additional defendants. In early 2010, the trial court granted Plaintiff’s amended motion and allowed him to add the five new defendants to the complaint. However, shortly after the court granted his leave to amend, Plaintiff added a sixth defendant without the court’s permission. All six defendants petitioned the Supreme Court for an interlocutory appeal concerning the trial court’s order that denied the defendants’ Motion for Summary Judgment, or Alternatively, Motion to Strike Second Amended Complaint and Dismiss First Amended Complaint. The defendants argued that, because the original parties settled with Plaintiff prior to his motions for leave to amend, the trial court improperly allowed the filing of the First Amended Complaint to add new parties. The defendants also argued that because Plaintiff did not seek court approval in filing his Second Amended Complaint, that complaint should be struck. Upon review, the Supreme Court found that the trial court abused its discretion in allowing Plaintiff to file his Second Amended Complaint, because he was required to obtain court approval. However, the trial court did comply with procedural rules when it allowed Plaintiff to file his First Amended Complaint, because McGraw filed his motion before all of the original parties were dismissed with prejudice. View "Lone Star Industries, Inc. v. McGraw" on Justia Law

Defendant Frederick Watts was convicted of felony fleeing or eluding a law enforcement officer in a motor vehicle and was sentenced to five years in custody, with two years suspended and three years of post-release supervision. On appeal, he argued that his conviction for felony fleeing subjected him to double jeopardy, because he previously had pled guilty to reckless driving in the Lauderdale County Justice Court. He also argued that the evidence was insufficient to support a guilty verdict. Finding no reversible error, the Supreme Court affirmed Defendant’s conviction and sentence. View "Watts v. Mississippi" on Justia Law

Defendant Damien Anderson (also known as Damien Wise) was convicted of murder arising from the homicide of Darnell “Sporty” Smith. Defendant contended the circuit court erred when it refused to grant a jury instruction on the lesser-included offense of manslaughter. He stated that the trial court improperly forced the defense to choose between manslaughter and self-defense instructions. However, because no reasonable jury could have found the defendant guilty of the lesser-included offense, the Supreme Court found no error and affirmed the circuit court’s judgment. View "Anderson a/k/a Wise v. Mississippi" on Justia Law

Defendant Deric Bailey was convicted by a jury of deliberate-design murder for which he was sentenced to life in prison. On appeal, Defendant's conviction and sentence were reversed by the Court of Appeals and the case was remanded for a new trial. At his second trial, Defendant again was convicted of deliberate-design murder and sentenced to life in prison. The trial court denied his motion for judgment notwithstanding the verdict, or in the alternative, a new trial, and Defendant timely filed this appeal. Defendant Bailey presented five issues on appeal to the Supreme Court: (1) whether the trial court erred in denying certain jury instructions; (2) whether the trial court erred in excluding from evidence the statement Defendant gave at the time of his arrest; (3) whether the jury selection process was constitutionally infirm under "Batson"; (4) whether the trial court erred in denying Defendant's motion to dismiss for failure to grant a speedy trial; and (5) whether Bailey was deprived of his right to a fair trial, or at the very least, denied his right to a fair and impartial judge. Upon review, the Supreme Court found that Defendant's claims were without merit, and affirmed Defendant's conviction and life sentence. View "Bailey v. Mississippi" on Justia Law

After After Corey Lee failed to appear at his divorce hearing, the chancellor granted his wife's complaint for divorce and divided the marital property. On appeal, Mr. Lee argued, among other things, that the chancellor erred by not making the findings of fact and conclusions of law required by case law. The Court of Appeals affirmed, finding that Mr. Lee's claim was procedurally barred for failing to raise the issue before the chancellor. But because Mr. Lee did raise the issue, and because the chancellor's failure to make findings of fact and conclusions of law was manifest error, the Supreme Court reversed the appellate court's decision and remanded the case for further proceedings. View "Lee v. Lee" on Justia Law