Justia Mississippi Supreme Court Opinion Summaries

Donald Quinn was indicted for the sexual battery of his seventeen-year-old niece, resulting in her pregnancy. The indictment was amended to reflect the crime occurred between July 1, 2015, and May 25, 2016. Pretrial motions included the exclusion of hearsay statements from the victim and her mother, who were unavailable to testify. The trial court allowed limited testimony from Detective Neal and admitted DNA evidence linking Quinn to the child.The Hinds County Circuit Court convicted Quinn, sentencing him to twenty years, with ten years suspended. Quinn's motion for judgment notwithstanding the verdict or a new trial was denied. On appeal, the Court of Appeals reversed the conviction, citing insufficient proof of venue and potential issues with witness testimony and evidence admission.The Supreme Court of Mississippi reviewed the case on certiorari. The court found that the trial court did not err in its rulings. It held that the State sufficiently proved venue through Detective Neal's unobjected-to testimony, which established the crime occurred in Hinds County. The court also found no error in admitting Dr. Schiro's DNA testimony, as he was sufficiently involved in the analysis and report. The amendment to the indictment was deemed proper, as it did not prejudice Quinn's defense. Carolyn Smith's testimony was allowed despite late disclosure, as it did not result in manifest injustice. The court also ruled that the trial court properly handled the State's closing argument and the use of birth certificates to refresh Smith's memory.The Supreme Court of Mississippi reversed the Court of Appeals' decision and reinstated and affirmed the Hinds County Circuit Court's judgment. View "Quinn v. State" on Justia Law

Hemphill Construction Company, Inc. (Hemphill) entered into a contract with the City of Jackson and subsequently subcontracted Interstate Carbonic Enterprises (ICE) for a project. Gay Lynn Harris, Jr., an owner and officer of ICE, was severely injured while working on the project in September 2020. Harris sought workers’ compensation benefits from Hemphill, but an Administrative Judge (AJ) ruled that Harris was not entitled to these benefits because he had voluntarily opted out of ICE’s workers’ compensation insurance coverage. Neither party appealed the AJ’s decision.In March 2022, Harris filed a negligence complaint against Hemphill in the Circuit Court of the First Judicial District of Hinds County. Hemphill moved to dismiss the complaint, claiming tort immunity under the exclusive remedy provision of the Mississippi Workers’ Compensation Act (MWCA). The trial court agreed and granted Hemphill’s motion to dismiss. Harris appealed, arguing that tort immunity did not apply and that judicial estoppel should apply. Hemphill contended that Harris had not exhausted his administrative remedies.The Supreme Court of Mississippi reviewed the case and found that Harris was not required to exhaust his administrative remedies before filing his negligence suit. The court held that Hemphill was entitled to tort immunity because it had contractually required ICE to obtain workers’ compensation insurance for its employees, thus satisfying the statutory requirement to secure payment under the MWCA. The court affirmed the trial court’s decision to dismiss Harris’s negligence claim against Hemphill. View "Harris v. Hemphill Construction Company, Inc." on Justia Law

The National Collegiate Athletic Association (NCAA) conducted an investigation into the University of Mississippi's football program, which included allegations against Barney Farrar, an assistant athletics director. The NCAA found Farrar guilty of multiple recruiting violations and issued a five-year show-cause order, restricting his employment in recruiting roles at NCAA member institutions. Farrar appealed the decision, but the NCAA's Infractions Appeals Committee upheld the findings and penalties.Farrar then filed a lawsuit in the Circuit Court of Lafayette County, alleging negligence, denial of a fair hearing, malicious interference with employment, denial of due process under the Mississippi Constitution, and usurpation of judicial function. The trial court granted summary judgment in favor of the NCAA on all claims except for malicious interference with employment and denial of due process. The NCAA petitioned for an interlocutory appeal on these two issues.The Supreme Court of Mississippi reviewed the case and applied a de novo standard of review. The court held that the NCAA is not a state actor and thus not subject to due process requirements under the Mississippi Constitution. The court also found that Farrar failed to provide evidence of malice necessary to support his claim of malicious interference with employment. Consequently, the court reversed the trial court's denial of summary judgment and rendered judgment in favor of the NCAA. View "National Collegiate Athletic Association v. Farrar" on Justia Law

Holly Mitchell was found guilty of second-degree murder and possession of methamphetamine after she shot and killed her husband, Shawn Mitchell, in their home while holding their three-year-old daughter. Holly claimed she acted in self-defense because Shawn was violent and had been using meth. Witnesses testified about the couple's tumultuous relationship, marked by drug use and domestic violence. Holly's defense argued the shooting was accidental, while the prosecution presented evidence of premeditation.The Marion County Circuit Court jury convicted Holly of second-degree murder. During deliberations, the jury expressed confusion about the instructions regarding second-degree murder and manslaughter. The trial court provided clarifications, but Holly's defense did not object to the court's responses. Holly appealed, arguing that the jury instructions were confusing and that her trial counsel was ineffective for not requesting additional instructions on imperfect-self-defense and culpable-negligence manslaughter.The Supreme Court of Mississippi reviewed the case and found no reversible error in the jury instructions, stating they were clear and properly guided the jury's deliberations. The court also noted that the jury ultimately reached a unanimous decision. Regarding the ineffective assistance of counsel claim, the court determined that the issue was best addressed in a post-conviction proceeding due to the lack of a fully developed record on direct appeal.The Supreme Court of Mississippi affirmed Holly's conviction for second-degree murder, dismissing her ineffective assistance of counsel claim without prejudice, allowing her to raise it in a post-conviction proceeding if she chooses. View "Mitchell v. State" on Justia Law

Caleb Corrothers was convicted of two counts of capital murder and one count of aggravated assault after attacking Tonya Clark’s family, resulting in the deaths of her husband and son. The jury sentenced him to death for the murders and life for the assault. Corrothers appealed, but the Supreme Court of Mississippi affirmed his convictions and sentences.Corrothers then sought post-conviction relief, raising multiple issues. The Supreme Court of Mississippi denied all but one claim, which alleged that a female juror had improperly communicated with Clark during the trial. The court granted a hearing on this juror-bias claim. Six years later, an evidentiary hearing was held where Corrothers presented two witnesses, his mother and cousin, who testified they saw the juror mouth “we got it” to Clark. The trial judge found these witnesses not credible due to their personal interest in the case and denied post-conviction relief.Corrothers appealed this decision, arguing that the trial judge improperly disregarded his witnesses' testimony and that his right to compulsory process was denied. The Supreme Court of Mississippi found that the trial judge did not exclude the testimony but rather found it not credible, a determination to which the court must defer. The court also held that the procedural framework established in Gladney v. Clarksdale Beverage Co. applied to Corrothers’s juror-bias claim, and the trial judge did not err in denying additional juror interviews.Ultimately, the Supreme Court of Mississippi affirmed the trial court’s denial of Corrothers’s post-conviction relief, concluding that Corrothers failed to present credible evidence of juror bias. View "Corrothers v. State" on Justia Law

Hurricane Katrina destroyed Paul and Sylvia Minor’s home in 2005. The Minors had a homeowner’s insurance policy with United Services Automobile Association (USAA) that covered wind damage but excluded storm surge or flood damage. USAA issued payments for wind damage but not for storm surge or flood damage, leading to a dispute. The Minors claimed a total loss due to wind and demanded policy limits. In 2013, a jury awarded the Minors $1,547,293.37 in compensatory damages.The Minor Estate appealed a pretrial order granting partial summary judgment to USAA on the Minors’ bad faith claim. The Mississippi Court of Appeals reversed the trial court’s decision, finding a genuine issue of material fact regarding USAA’s denial and delay of payment. The case was remanded for further proceedings on the bad faith claim. On remand, a jury awarded the Minors $10,000,000 in punitive damages and $457,858.89 in extra-contractual damages (attorneys’ fees). USAA appealed, and the Minor Estate cross-appealed the denial of its post-trial motion for additional attorneys’ fees.The Supreme Court of Mississippi reviewed the case and found no reversible error, affirming the jury’s award of $10,457,858.89 in damages. The court also reversed and rendered attorneys’ fees on behalf of the Estate in the amount of $4,500,000, plus post-judgment interest. The court held that the trial judge did not err in submitting the issue of punitive damages to the jury and that the $10 million punitive damages award was not unconstitutionally disproportionate. The court also found no error in the jury’s award of extra-contractual damages and no errors warranting a new trial. View "United Services Automobile Association v. Estate of Minor" on Justia Law

Jessie D. Boyett Jr., an inmate serving consecutive sentences, filed a complaint against the Mississippi Department of Corrections (MDOC) seeking to have his sentences commuted and to be declared eligible for parole. Boyett's requests were initially rejected by the MDOC's Administrative Remedy Program (ARP) for containing multiple complaints and unclear legal language. After resubmitting his request and receiving another rejection, Boyett filed a complaint with the Hinds County Circuit Court, which dismissed his case for lack of jurisdiction, stating it should be resolved in the county where he was incarcerated.The Court of Appeals upheld the Circuit Court's dismissal, agreeing that Boyett filed his petition in the incorrect venue and had not exhausted his administrative remedies. The appellate court determined that the proper venue for challenging an MDOC decision is where the prisoner is housed and that Boyett failed to properly file his ARP request and receive a final decision from MDOC.The Supreme Court of Mississippi reviewed the case on certiorari, focusing on the issue of venue. The court found that, according to Mississippi Code Section 11-11-3(1)(a)(i), venue was proper in the First Judicial District of Hinds County, where the defendants reside. However, the court affirmed that Boyett had not exhausted his administrative remedies before filing his complaint. Consequently, the Supreme Court affirmed in part and reversed in part the judgments of the Court of Appeals and the Circuit Court of the First Judicial District of Hinds County. The court clarified that venue for such cases is proper where a defendant resides or where a substantial act causing the injury occurred. View "Boyett v. Cain" on Justia Law

In November 2021, Mettro Johnson filed a motion in Coahoma County Chancery Court to set aside a 2002 order that determined paternity and required him to pay child support, arguing the order was void due to insufficient service of process. The court found the 2002 order void for lack of personal jurisdiction because Johnson was served one day short of the required thirty-day notice period.The Court of Appeals affirmed the chancery court's decision in a divided ruling, agreeing that the 2002 order was void due to insufficient service of process. The Mississippi Department of Human Services (MDHS) filed a petition for writ of certiorari, which the Supreme Court of Mississippi granted.The Supreme Court of Mississippi reviewed the case and agreed that the chancery court lacked personal jurisdiction over Johnson due to insufficient service of process. However, the court found that Johnson waived his challenge to personal jurisdiction by entering into a stipulated agreement in 2003, which acknowledged the validity of the 2002 order. Consequently, the Supreme Court reversed the judgments of the Coahoma County Chancery Court and the Court of Appeals and remanded the case for further proceedings consistent with its opinion. View "Department of Human Services v. Johnson" on Justia Law

Nolan D. Palmer appealed a circuit court order enforcing sureties' liability related to a fee dispute among attorneys Barry Wade Gilmer, Seth Little, and Chuck McRae. McRae had initially sued Barry in Hinds County Chancery Court, and Barry subsequently filed a complaint in Madison County Circuit Court against Little, McRae, and McRae's attorneys, Michele Biegel and Bettie Ruth Johnson. The Madison County Circuit Court transferred the entire suit to Hinds County Chancery Court, but the Mississippi Supreme Court reversed this transfer for the claims against Biegel and Johnson, remanding the case back to Madison County Circuit Court. On remand, the circuit court dismissed Barry's complaint against Biegel and Johnson as frivolous and ordered Barry to pay their costs.Barry appealed and filed an appeal bond with supersedeas, signed by Barry, Matthew Gilmer, and Palmer. The bond was not signed by the circuit clerk. The Mississippi Supreme Court affirmed the circuit court's orders, and Biegel and Johnson moved to enforce the sureties' liability, claiming Barry had not satisfied the judgments. The circuit court found the bond enforceable as a contract, holding Barry and Palmer liable.Palmer appealed, arguing he was denied due process, the bond was invalid, and the circuit court erred in enforcing the bond as a contract. The Mississippi Supreme Court reviewed the case de novo and found that Palmer waived his arguments by failing to appear or defend the motion in the circuit court. The court held that Palmer was provided due process as required under Rule 8(d) and affirmed the circuit court's order enforcing sureties' liability. View "Palmer v. McRae" on Justia Law

M.M. and J.B., Sr. were once married and had a daughter, L.B. After their divorce, J.B., Sr. married P.B. L.B. gave birth to J.J.W.B. in May 2018, but the child was removed from her custody due to her drug addiction. In August 2018, L.B.'s brother sought custody of J.J.W.B., and temporary custody was placed with J.B., Sr. and P.B. M.M. sought visitation rights in September 2018. The court granted custody to J.B., Sr. and P.B. and visitation rights to M.M. in October 2018. In July 2019, custody was again placed with J.B., Sr. and P.B., with continued visitation for M.M.In October 2020, J.B., Sr. and P.B. filed for voluntary termination of parental rights and adoption of J.J.W.B., which was granted in December 2020 without notifying M.M. M.M. filed a petition for contempt in January 2021 for not being allowed visitation, and later, in February 2022, she filed a motion to set aside the adoption. The Smith County Chancery Court denied the motions to dismiss filed by J.B., Sr. and P.B., reasoning that M.M. should have been notified of the adoption proceedings and that her visitation rights were not terminated by the adoption order.The Supreme Court of Mississippi reviewed the case. The court held that M.M.'s motion to set aside the adoption was untimely and that she was not a necessary party to the adoption proceedings. Therefore, the court reversed the denial of the motion to dismiss M.M.'s motion to set aside the adoption. However, the court affirmed the denial of the motion to dismiss M.M.'s contempt action, holding that the adoption did not extinguish her visitation rights. The case was remanded to the chancery court for further proceedings to determine visitation post-adoption. View "In Re The Adoption of J.J.W.B." on Justia Law