Justia Mississippi Supreme Court Opinion Summaries

In 2003, Respondent Cedric Byrd misjudged a turn along a Rankin County highway. The trailer he was towing got stuck in the highway. A car in which Jonathan Dooley was traveling with his mother collided with the trailer, killing Jonathan instantly. On behalf of Jonathan's heirs, Leah Dooley, Jonathan's mother, filed a wrongful death action against Mr. Byrd and his employer Independent Roofing Systems. A jury returned a verdict in favor of Mr. Byrd and Independent Roofing. The trial court denied Ms. Dooley's post-trial motions, and she appealed to the Supreme Court. Ms. Dooley argued that there were multiple errors at trial that ended with a verdict against the weight of the evidence presented. Upon review of the trial court record, the Supreme Court agreed that the errors at trial warranted a new trial. Of note, the Court found that Jonathan's heirs were not allowed to fully participate in the proceedings. On this basis, the Supreme Court reversed the trial court's judgment in this case and remanded the case for further proceedings.

Anthony Smith died in a plane crash in 2001. His estate contained two separate life insurance policies. Mr. Smith's father Raymond was named as sole beneficiary of one policy, and Mr. Smith's ex-wife Ruth was named as beneficiary on the other. At the time of his death, Mr. Smith owned a life estate in 657 acres of land in Tate County. One hundred and sixty of the acres were set aside in fee simple for Raymond and his wife Dorothy as part of their homestead. This case came before an appellate court three separate times. Each time, the issue before the court involved the proper way to apportion the tax liability among the beneficiaries to the estate. The Supreme Court issued an opinion holding that taxes should be based on the taxable estate, rather than the gross estate. On remand, the Estate filed two motions demanding that Raymond and Ruth reimburse the Estate for taxes paid plus interest on the insurance policies. Raymond filed a motion demanding that the Estate pay him for rent for the time he was excluded from his homestead. The chancery court ultimately held that Raymond and Ruth were responsible for their portions of tax liability owed to the Estate, and that Raymond was entitled to twenty-four months' rent. The Estate appealed to the Supreme Court. Upon careful consideration of the case record, the Supreme Court affirmed the chancery court.

Respondent Tim Norris failed to pay his 2005 property taxes on his restaurant in Jackson. In 2006, Sass Muni purchased the restaurant in a tax sale. When Mr. Norris did not redeem the property within the statutory two-year period, a tax deed was issued to Sass Muni, who then deeded the property to Petitioner Rebuild America, Inc. When Rebuild America filed suit to confirm its title, Mr. Norris intervened, arguing that he was never served with notice of the tax sale. He moved to have the tax sale set aside. The chancellor set the tax sale aside, and Rebuild America appealed. The appellate court affirmed the chancery court's ruling. Rebuild America appealed again to the Supreme Court. The Supreme Court agreed with the appellate court's analysis of the issues presented on appeal, and affirmed its holding.

Petitioner Barry Gregg challenged a Workers’ Compensation Commission (Commission) holding that denied him permanent partial disability benefits. Petitioner was injured on the job for Respondent Natchez Trace Electric Power (Natchez) and was unable to satisfactorily return to his job nor earn on-call compensation. Petitioner unsuccessfully appealed the Commission’s decision to the circuit court and the Court of Appeals. On appeal to the Supreme Court, Petitioner argued that the Commission erred in reaching its decision. In the decision adopted by the Commission, the administrative law judge observed that Petitioner made more money after his injury than before he was injured. The appellate court affirmed the Commission’s decision on the basis of a presumption that because of that earning discrepancy, Petitioner failed to prove that he suffered a loss of “wage-earning capacity.” The Supreme Court found that the Commission erred by considering Petitioner’s higher wage post-injury as determinative of his earning capacity. The Court found that Petitioner had rebutted the presumption regarding his earning capacity. Subsequently, the Court reversed both the Commission’s and the appellate court’s holdings and remanded the case for further proceedings.

Plaintiff-Appellee Terrance Shanks filed a personal-injury action against Defendants-Appellants Kimball Glassco Residential Center and van driver Vera Richardson on behalf of his mother Lois Shanks. Ms. Shanks was injured when the van Ms. Richardson was driving went out of control. Ms. Richardson moved to dismiss the complaint, asserting that the action was barred by a one-year statute of limitations under state tort law. In its answer to the action, Kimball Glassco also raised the statute of limitations as a defense and argued that it was a state entity entitled to a level of immunity under the state tort law. The trial court denied Ms. Richardson's motion to dismiss and held that both Defendants had waived the statute of limitations defense earlier in the litigation. Furthermore, the court found that the state tort law did not give either Defendant immunity from liability. Upon consideration of the briefs and the applicable legal authority, the Supreme Court found that the trial court erred by finding that Defendants waived the statute of limitations as their defense. The Court found that Mr. Shanks filed his complaint one year after the expiration of the statute. Accordingly, the Court reversed the trial court's order, and rendered judgment in favor of Defendants.

Defendant Gregory Redmond appealed his conviction of statutory rape. He was sentenced to life. On appeal to the Supreme Court, Defendant argued that the trial court made errors by admitting some and excluding other testimony that was ultimately prejudicial to his case. Upon consideration of the record and the applicable legal authority, the Supreme Court found no error by the trial court. The Court affirmed Defendant's conviction and sentence.

Defendant Dennis Taylor appealed his conviction for conspiracy and robbery. He was sentenced to fifteen years. On appeal to the Supreme Court, Defendant argued that the verdicts against him at trial were against the weight and sufficiency of the evidence. Upon consideration of the arguments and the applicable legal authority, the Supreme Court found that the evidence was sufficient to support the jury's verdicts, and that the verdicts were not against the overwhelming weight of the evidence. The Court affirmed Defendant's conviction and sentence.

Dr. Daniel Dare appealed a ruling of the Chancery Court that denied him the ability to intervene in the modification of a marital property agreement entered into by Paul and Sharon Stokes. Mr. and Mrs. Stokes were married in 1985. In 2007, Mrs. Stokes had an affair with Dr. Dare. Shortly after the affair began, Mr. Stokes filed for divorce. With the entry of a divorce decree, the Chancery Court incorporated a child-custody and property-settlement agreement that was "executed" by Mr. and Mrs. Stokes. Pertinent to the Supreme Court's review of this matter was a "covenant not to sue" included in the property agreement. Mr. Stokes filed a petition to modify the property agreement and sought to delete that part of the provision that barred him from bringing suit against "any other person for alienation or affection." Mrs. Stokes did not contest Mr. Stokes' petition, and the court deleted the term "any other person." Mr. Stokes then sued Dr. Dare for "alienation of affection." Dr. Dare sought to intervene in Mr. Stokes' modification matter. The court held that Dr. Dare was not a party to the divorce or the property agreement, and as such, had no legally cognizable interest in the divorce. Dr. Dare argued on appeal to the Supreme Court that the modified "covenant not to sue" implicitly targeted Dr. Dare as a party, and that he should be allowed to intervene in the modification proceedings. The Supreme Court agreed with the Chancery Court that Dr. Dare had no legally protected interest in the Stokes' divorce and affirmed the lower court's decision.

A grand jury indicted Defendant Harold Hargett for selling marijuana and hydrocodone. A jury found Defendant guilty, and he was sentenced as a habitual offender to six years for the marijuana charge, and sixty years for the hydrocodone charge. The appellate court affirmed Defendant's sentence. Defendant appealed to the Supreme Court by arguing that the trial court erred by admitting testimony that referenced certain "prior bad acts" that should have been excluded. Before trial began, defense counsel argued in a motion to exclude evidence that Defendant's prior convictions would be too prejudicial. The trial court granted the motion. Despite the ruling, the State continually elicited inadmissible testimony that referenced the prior convictions. The Supreme Court reversed the decisions of the trial and appellate courts and remanded the case for a new trial. The Court found that the testimony that referenced Defendant's prior bad acts should have been excluded.

In 2007, Plaintiff Lyshell Wilson entered Defendant CitiTrends' clothing store. While shopping, Ms. Wilson was brutally injured by Defendant Jocelyn Howard, who attacked her with a pair of scissors. Ms. Howard moved to dismiss Ms. Wilson's claims, arguing that Ms. Wilson failed to file her complaint within a one-year statute of limitations for assault and battery. Ms. Wilson denied she sued for assault and battery. Instead, she sued on a negligence claim. The trial court denied Ms. Howard's motion to dismiss. On appeal to the Supreme Court, Ms. Howard argued that Ms. Wilson attempted to circumvent the statute of limitations by characterizing her claim as one for negligence when it was really assault and battery. Ms. Howard maintained that Ms. Wilson's claim is barred by the statute of limitations. The Supreme Court agreed with Ms. Howard. The Court held that the trial court erred in denying Ms. Howard's motion to dismiss. The Court remanded the case for further proceedings.