Justia Mississippi Supreme Court Opinion Summaries

Alpresteon Billings was hired as the executive director of the Housing Authority of Yazoo City, Mississippi, with an anticipated five-year contract and a starting salary of $65,000. However, the terms of this contract were not recorded in the Housing Authority’s board minutes. Billings was terminated from her position on February 20, 2019, and subsequently sued the Housing Authority for breach of contract, among other claims.The Yazoo County Circuit Court partially granted and partially denied the defendants' motion for summary judgment. The court found that the commissioners were immune under the Mississippi Tort Claims Act and dismissed the claims against them. However, the court denied summary judgment on Billings’s breach-of-contract claim against the Housing Authority, finding that there were genuine issues of material fact.The Supreme Court of Mississippi reviewed the case and applied the rule that public boards can only act through their minutes, which must contain enough terms and conditions of a contract to determine the liabilities and obligations of the parties without resorting to other evidence. The court found that the Housing Authority’s minutes did not contain any terms of Billings’s alleged employment contract, such as her name, salary, or contract duration. Therefore, Billings’s breach-of-contract claim failed as a matter of law.The Supreme Court of Mississippi reversed the trial court’s denial of summary judgment on Billings’s breach-of-contract claim and rendered judgment in favor of the Housing Authority. View "Housing Authority of The City of Yazoo City v. Billings" on Justia Law

Stewart Dubose took over Radco Fishing and Rental Tools, Inc. from his father, John Dubose Sr., and sought to increase the company's cash flow by engaging Commercial Resources, Inc. for an accounts receivable line of credit. Stewart personally guaranteed the debt. Commercial Resources advanced over two million dollars to Radco, but payments ceased in 2015. John Dubose later took control of Radco and began liquidating its assets. Stewart and John settled a separate dispute, agreeing to sell Radco to Dynasty Energy Services, LLC, which assumed Radco's liabilities.Commercial Resources filed a lawsuit against Radco, Stewart, and Dynasty for the outstanding debt. Radco and Dynasty counterclaimed, alleging various defenses and claims against Commercial Resources. The case proceeded to trial, where the court granted a directed verdict against Radco and Stewart, finding them liable for the debt. The jury found Dynasty liable for $448,528.60 but awarded zero damages against Radco and Stewart. The trial court later amended the judgment to hold Radco, Stewart, and Dynasty jointly liable for the debt.The Supreme Court of Mississippi reviewed the case and affirmed the trial court's decisions. The court found no error in the trial court's grant of partial summary judgment dismissing Radco and Dynasty's affirmative defenses due to their delay in pursuing them. The court also upheld the trial court's decision to admit parol evidence, finding the Purchase Agreement ambiguous. The court affirmed the directed verdict against Radco and Stewart, agreeing that Stewart had authority to enter the agreement and that Radco ratified it. The court found no error in the jury instructions or the trial court's denial of post-trial motions. The court also upheld the trial court's award of attorneys' fees to Commercial Resources, finding it appropriate under the contractual provisions. View "Radco Fishing and Rental Tools, Inc. v. Commercial Resources, Inc." on Justia Law

Raymond Phillips was convicted of attempted aggravated assault after Ronald Brown reported that Phillips had shot at him in Hattiesburg, Mississippi. Brown called 911, and officers arrived to find him distraught. Officer Ianconangelo found a shell casing at the scene, and Officer Truss, who knew Phillips, identified him as the suspect. Phillips was later found driving his truck, which contained a firearm matching the shell casing. Detective Daniels reviewed NOLA camera footage showing Phillips pointing and firing a gun in Brown's direction. The firearm and shell casing were confirmed to match by a forensic examiner.The Forrest County Circuit Court found Phillips guilty of attempted aggravated assault and possession of a weapon by a convicted felon. Phillips was sentenced to twenty years for the assault and ten years for the weapon charge, to be served concurrently. Phillips filed a motion for judgment notwithstanding the verdict or a new trial, which was denied.The Supreme Court of Mississippi reviewed the case. Phillips argued that his Sixth Amendment right to confrontation was violated by the admission of body-camera footage and a search warrant affidavit containing Brown's statements. The court found that the statements on the body-camera footage were non-testimonial as they were made during an ongoing emergency. The court also found that the admission of the search warrant affidavit, which included comments on Phillips's post-Miranda silence, was harmless error given the overwhelming evidence against him. Phillips's claims of cumulative error and ineffective assistance of counsel were also rejected. The court affirmed the lower court's decision, upholding Phillips's conviction. View "Phillips v. State" on Justia Law

Mark Lovil, the manager of R.K. Metals, LLC, signed a commercial lease with E&E, Co. Inc. in 2015 in his representative capacity. The lease did not include a personal guaranty or arbitration clause. R.K. Metals became delinquent in rent payments, leading E&E to require a new lease in 2018, which included both a personal guaranty and an arbitration clause. Lovil signed the new lease as president of R.K. Metals, but R.K. Metals claimed they were unaware of the new clauses until the final version was delivered.R.K. Metals filed a complaint in the Lee County Circuit Court in May 2020, seeking declaratory relief and asserting breach-of-contract claims. The circuit court found the lease enforceable and ordered arbitration. E&E sought to include Lovil personally in the arbitration, leading to a determination of his status as guarantor. The circuit court granted E&E’s Motion for Summary Judgment, finding Lovil personally liable as guarantor and a necessary party to arbitration.The Supreme Court of Mississippi reviewed the case de novo. The court held that Lovil’s signature on the lease, despite his corporate designation, bound him personally as guarantor due to the clear language of the guaranty clause. The court also found that Lovil, as personal guarantor, was bound by the arbitration clause. The court applied the doctrine of equitable estoppel, noting Lovil’s close legal relationship with R.K. Metals, and concluded that he must participate in arbitration.The Supreme Court of Mississippi affirmed the circuit court’s judgment, holding that Lovil is personally bound as guarantor and compelled to participate in arbitration. View "R.K. Metals, LLC v. E & E Co., Inc." on Justia Law

In 2012, the victim's mother rekindled a relationship with Cayce William Jones and moved into his house with her two children. After moving in, Jones sexually battered the victim. A grand jury indicted Jones on one count of sexual battery and one count of fondling. A Monroe County jury convicted Jones on both counts.Jones appealed, arguing that he received ineffective assistance of counsel because his trial counsel failed to file post-trial motions. The Monroe County Circuit Court handled the initial trial and conviction.The Supreme Court of Mississippi reviewed the case. Jones contended that his trial counsel was constitutionally ineffective for not filing a motion for a new trial. The court noted that ineffective-assistance-of-counsel claims are sometimes better suited for post-conviction relief proceedings but can be addressed on direct appeal if the record affirmatively shows ineffectiveness or if the parties stipulate that the record is adequate. The court found that the record showed Jones's claim was without merit and addressed it on direct appeal.The court applied the Strickland v. Washington standard, which requires showing that counsel's performance was deficient and that this deficiency prejudiced the defense. Jones failed to demonstrate a reasonable probability that a motion for a new trial would have succeeded. The court noted that the evidence against Jones, including the victim's testimony and expert testimony, countered his arguments. The court concluded that the trial involved conflicting testimony, which the jury properly resolved.The Supreme Court of Mississippi affirmed Jones's conviction and sentence, finding that he did not show that his counsel's decision not to file a motion for a new trial prejudiced his defense. View "Jones v. State of Mississippi" on Justia Law

Zachary Minor was charged with possession of marijuana and trafficking of THC after a package containing these substances was delivered to a residence in Natchez, Mississippi. Agents from the Mississippi Bureau of Narcotics observed the delivery and arrested Mario Hartwell, who retrieved the package. Minor was found in the truck with Hartwell, and evidence from Minor's phone linked him to the package. A grand jury indicted Minor and Hartwell on multiple counts, and Minor's trial was severed from Hartwell's.The Adams County Circuit Court conducted a jury trial, during which the State made several errors, including commenting on Minor's right to remain silent, eliciting inflammatory testimony about the effects of edibles on children, and introducing hearsay evidence from Hartwell. The jury found Minor guilty of possession with intent to distribute and trafficking THC. Minor's motions for a mistrial and a new trial were denied, and he was sentenced to concurrent terms of ten and twenty years.The Court of Appeals affirmed Minor's conviction, finding that the errors were either waived or harmless. However, a dissenting opinion argued that the cumulative effect of the errors warranted a new trial. Minor then petitioned for certiorari.The Supreme Court of Mississippi reviewed the case and found that the cumulative effect of the errors deprived Minor of a fair trial. The court held that the State's actions, including commenting on Minor's right to remain silent, eliciting prejudicial testimony, and introducing inadmissible hearsay, constituted prosecutorial misconduct. The court reversed the Court of Appeals' decision and remanded the case to the circuit court for a new trial. View "Minor v. State of Mississippi" on Justia Law

Shanta Webster filed a complaint in the Grenada County Circuit Court against the University of Mississippi Medical Center-Grenada (UMMC-Grenada) and Drs. Aimee Watts and Kimberly Farmer, alleging medical negligence in the performance of a hysterectomy and post-operative care. Webster served the complaint to Dr. Watts, Dr. Farmer, and Dodie McElmurry, the CEO of UMMC-Grenada. The defendants requested an extension to answer the complaint and later claimed immunity under the Mississippi Tort Claims Act (MTCA). Webster argued that service of process was proper under Rule 4(d)(8) of the Mississippi Rules of Civil Procedure.The Grenada County Circuit Court dismissed the complaint, ruling that service of process was improper because it was not made to the Attorney General as required by Rule 4(d)(5) for state institutions. Webster appealed the dismissal, maintaining that UMMC-Grenada is a community hospital and that service on the CEO was sufficient.The Supreme Court of Mississippi reviewed the case de novo and upheld the trial court's decision. The court found that UMMC-Grenada is not a separate entity but a part of UMMC, a state institution. Therefore, service of process should have been made to the Attorney General under Rule 4(d)(5). Webster failed to serve the Attorney General within the 120-day period required by Rule 4(h), rendering the service invalid. Additionally, the court noted that Drs. Watts and Farmer, acting within the scope of their employment, were immune from personal liability under the MTCA.The Supreme Court of Mississippi affirmed the trial court's order of dismissal, concluding that proper service of process was not effected, and the individual defendants were immune from liability. View "Webster v. University of Mississippi Medical Center Grenada" on Justia Law

Linda Lee owned a motel in Pascagoula, Mississippi, which had deteriorated significantly and was being used improperly, attracting vagrants and drug users. The city council ordered the demolition of the motel after a hearing, citing it as a menace to public health and safety. Lee did not attend the hearing, but her son did. The city council decided the motel was beyond repair and ordered its demolition.Lee appealed the city council's decision to the Jackson County Circuit Court, arguing that the city failed to provide substantial evidence and did not comply with statutory notice provisions. The Circuit Court affirmed the city's decision. Lee then appealed to the Court of Appeals, which found that the city’s notice was insufficient and reversed and remanded the case for further determination.The Supreme Court of Mississippi reviewed the case on certiorari. The court found that the appeal was moot because the motel had already been demolished by a new owner, as admitted by Lee in her appellate filings. Additionally, Lee lacked standing to pursue the appeal because she had transferred the property to her son on the day of the city council meeting and no longer had any interest in it. Consequently, the Supreme Court of Mississippi vacated the Court of Appeals' decision and dismissed Lee's appeal. View "Lee v. The City of Pascagoula, Mississippi" on Justia Law

In November 2019, Sarah and her two minor children lived with her boyfriend, William Jeffrey Knight. Suspecting infidelity, Sarah searched Knight's phone and discovered a pornographic video of her twelve-year-old daughter, Jane. Sarah took the phone to the Petal Police Department, where officers viewed the video and conducted further investigation. Knight was indicted on two counts of child exploitation and one count of touching a child for lustful purposes.The Forrest County Circuit Court held a jury trial, where Knight was found guilty on all counts. He was sentenced to ninety-five years in prison and required to register as a sex offender. Knight filed motions to suppress evidence obtained from his phone, arguing that the search violated his Fourth Amendment rights. The motions were denied, and Knight appealed the decision.The Supreme Court of Mississippi reviewed the case. Knight raised several issues on appeal, including the legality of the warrantless search of his phone, prosecutorial misconduct, the validity of the search warrants, the presentation of false testimony, the proportionality of his sentence, and claims of ineffective assistance of counsel. The court found that the private search doctrine applied to the warrantless search of Knight's phone, as the police did not exceed the scope of Sarah's initial search. The court also determined that the prosecutor's conduct during cross-examination did not amount to misconduct and that the search warrants, despite clerical errors, were valid. The court found no evidence that the State knowingly presented false testimony and ruled that Knight's sentence was within statutory limits.The Supreme Court of Mississippi affirmed Knight's convictions and sentences, finding no cumulative error that would warrant reversal. View "Knight v. State" on Justia Law

In October 2020, Terrance Watts was indicted for the first-degree murder of his half-brother, Yancy Williams, by a grand jury in Hinds County, Mississippi. The incident occurred at a Marathon gas station where Williams was shot in the head by Watts. Surveillance footage and witness testimonies indicated that Williams was intoxicated and aggressive, leading to a physical altercation with Watts. Watts later turned himself in and admitted to the shooting, claiming he panicked.The Hinds County Circuit Court tried Watts in July 2023, where he was convicted of first-degree murder and sentenced to life imprisonment. Watts filed a post-trial motion for a judgment notwithstanding the verdict or a new trial, which was denied by the trial judge. Watts then appealed, raising three issues: the sufficiency of the evidence, the propriety of jury instruction S-4 on deliberate design killing, and the propriety of jury instruction S-2 regarding malice aforethought inferred from the use of a deadly weapon.The Supreme Court of Mississippi reviewed the case and found no error. The court held that the evidence was sufficient to support the conviction, as a rational juror could find each element of first-degree murder beyond a reasonable doubt. The court also found that jury instruction S-4 was proper and did not prejudice Watts, as it accurately stated the law. Additionally, the court held that jury instruction S-2 did not improperly comment on the weight of the evidence, as it was consistent with established legal principles. Consequently, the Supreme Court of Mississippi affirmed the conviction and sentence. View "Watts v. State of Mississippi" on Justia Law