Justia Mississippi Supreme Court Opinion Summaries

This case involved a medical-malpractice suit brought by Jalena and Brian Taylor against Jalena’s OB/GYN, Dr. Donielle Daigle, and her clinic, Premier Women’s Health, PLLC. In 2017, Jalena was admitted to Memorial Hospital of Gulfport in active labor preparing to give birth. After pushing for two and a half hours, the baby’s head became lodged in the mother’s pelvis, and it was determined that a caesarean section was necessary. Following delivery of the child, Jalena’s blood pressure dropped, and her pulse increased. The nurses worked to firm Jalena’s uterus post delivery, but she continued to have heavy clots and bleeding. Jalena was given a drug to tighten the uterus, and an OR team was called to be on standby in the event surgery became necessary. Dr. Daigle called the OR team off after Jalena’s bleeding was minimal, and her uterus remained completely firm. But Jalena’s heart rate remained extremely elevated. Dr. Daigle allowed Jalena to go back to her room, and she checked her again, and the uterus was firm. A minute or two later, Jalena sat up and felt a gush of blood. Dr. Daigle prepared to perform a hysterectomy, There was still bleeding from the cervical area, which doctors decided they needed to amputate. Even after doing so, there was still bleeding because of a laceration extending into the vagina. When the vagina was sutured and incorporated into the repair of the vaginal cuff, the bleeding finally stopped. The Taylors allege that Dr. Daigle failed to adequately treat Jalena and, as a result, she cannot have any more children. A five-day jury trial was held in January 2021, and the jury returned a twelve-to-zero verdict in favor of Dr. Daigle and Premier. On appeal, the Taylors argued the trial court committed reversible error by: (1) refusing to grant their cause challenges of patients of Dr. Daigle and Premier, thus failing to give them a right to a fair and impartial jury; and (2) failing to find a deviation from the standard of care for failing to perform a proper inspection of a genital tract laceration. The Mississippi Supreme Court affirmed the jury verdict because it was reached on factual evidence in favor of Dr. Daigle and Premier by an impartial jury. "All twelve of the jurors agreed on the verdict, and the verdict was not against the overwhelming weight of the evidence. It should not be disturbed." View "Taylor v. Premier Women's Health, PLLC, et al." on Justia Law

Courtney Williams appeals her manslaughter conviction. James Williams, his pregnant daughter Courtney, and Courtney’s two children lived with James at James’s residence. James had recently allowed Courtney’s boyfriend, Cymonde “CJ” Sailer, to move in with them. On the night of September 1, 2019, Courtney, her daughter, and CJ were in Courtney’s bedroom watching television. Between 10:30-11:00 p.m., James discovered that CJ had fallen asleep in Courtney’s bed despite an agreement that CJ would sleep in Courtney’s son’s bedroom across the hall. An altercation occurred between James and Courtney. During the altercation, Courtney stabbed James twice in the back. When law enforcement arrived, Courtney advised that her father had attacked her and that she had stabbed her father in the back. One of the law enforcement officers then left to check on James. James was found deceased inside of his vehicle outside of his residence. He was in the driver’s seat, leaned over with his head down. A forensic pathologist who performed James' autopsy found his blood alcohol level was about one and one half times the legal limit. The physician opined the cause of death was “stabbing of the torso” and that the manner of death was homicide. Courtney was indicted and charged with the first-degree murder of James. The Mississippi Supreme Court determined the trial court erroneously refused Courtney's proposed jury instructions related to her right to stand her ground, her conviction and sentence were reversed and the case remanded for a new trial. View "Williams v. Mississippi" on Justia Law

Willie Manning was convicted in 1994 of two counts of capital murder while engaged in commission of a robbery for the murders of Jon Steckler and Tiffany Miller, and was sentenced to death. Manning appealed, asking the Mississippi Supreme Court to allow him to transfer DNA evidence gathered from the crime scene of the murders of Miller and Stecker to a different specialized lab for additional advanced DNA testing. After many years of pursuing options for DNA testing and fingerprint analysis of evidence used against him at trial, pursuant to Mississippi Code Section 99-39-5 (Rev. 2020), the Supreme Court partially granted Manning’s request for post-conviction collateral relief (PCR). Under the Court’s order, Manning proceeded with DNA analysis and fingerprint comparison utilizing the procedures set forth in the statute. For six years, Manning had DNA evidence tested and expert fingerprint analysis performed. After receiving allegedly inconclusive results, Manning appealed here the circuit court’s order denying his motion to transfer the DNA evidence to a different facility for additional DNA testing. The Supreme Court found the circuit court did not abuse its discretion and affirmed the denial of the request for additional testing. View "Manning v. State of Mississippi" on Justia Law

In September 2016, Christopher Strickland, Jr., a sophomore at Northwest Rankin High School, was at Choctaw Trails in Clinton, Mississippi, preparing to run a cross- country meet. Before the race, a wasp stung Christopher on the top of his head. According to Christopher, a lump began to form and his head felt tight, like it was swelling. Christopher told one of his coaches. According to affidavits submitted by the Rankin County School District (RCSD), two coaches and a registered nurse, who was there to watch her son race, examined Christopher’s head and found no evidence of a sting or adverse reaction. And Christopher assured them he was fine and wanted to run the race. But Christopher recalled only one coach examining him. And this coach told him to “man up” and run the race. Christopher ran the race. According to one of his coaches, she checked in on him at the mile marker. He responded that he was “okay, just hot.” According to Christopher, after the mile marker he began to feel dizzy. Then he fell, hitting his head. The same nurse attended to him. So did her husband, who was a neurologist. Christopher appeared to recover and rejoined his team after the race. But he later went to a doctor, who discovered injuries to his brain and spine. In January 2017, Christopher’s father, Christopher Strickland, Sr. (Strickland), sued RCSD on Christopher’s behalf. He alleged various breaches of duties in how RCSD employees acted both (1) after the wasp sting but before the race and (2) after Christopher’s fall. Specifically, Strickland alleged that, after the fall, RCSD employees failed to follow the district’s concussion protocol. The Mississippi Supreme Court surmised "much legal analysis has been aimed at whether the actions of two cross-country coaches were discretionary policy decisions entitled to immunity from suit under Mississippi Code Section 11-46-9(1)(d) (Rev. 2019)." But on certiorari review, the Court found this question to be moot: the alleged actions of the coaches do not establish any triable claim for negligence. For that reason, the Supreme Court affirmed the trial court’s grant of summary judgment to the Rankin County School District. View "Strickland v. Rankin County School District" on Justia Law

After Wilkinson County Senior Care changed ownership, it received the maximum per diem rate from the Mississippi Division of Medicaid (DOM) for a period of twenty months. The DOM notified Wilkinson County Senior Care multiple times that the maximum per diem rate it received during this time period was subject to adjustment based on its initial cost report. The DOM did not seek recoupment of the overpayment based on the adjustment until 2011. Wilkinson County Senior Care argued that this delay foreclosed the DOM from recouping the overpayment it received. The DOM and the chancery court both affirmed that the recoupment was allowable. Because no legal or equitable principles provide that the delay in this case forecloses recoupment, the Mississippi Supreme Court affirmed the decisions of the chancery court and the DOM. View "Wilkinson County Senior Care, LLC v. Mississippi Division of Medicaid" on Justia Law

Eugene Bullen was convicted of driving under the influence (DUI), second offense. He appealed to the County Court of Madison County. Following a bench trial, the trial judge found Bullen guilty and sentenced him to thirty days of imprisonment, a two year’s driver’s license suspension, an alcohol and drug assessment, six months supervised probation, eighteen months unsupervised probation, and eighty hours of community service within six months. Aggrieved by that decision, Bullen appealed to the Madison County Circuit Court. The circuit court held that the decision of the county court was supported by substantial evidence and was not manifestly wrong. Bullen then appealed to the Mississippi Supreme Court, arguing the trial court erred by not granting his motion to dismiss for insufficiency of the evidence. Bullen argued the State did not meet its burden to prove beyond a reasonable doubt that he was intoxicated. After review, the Supreme Court held the trial judge was presented with sufficient evidence to find Bullen guilty of violating Mississippi Code Section 63-11-30(1)(a), and accordingly, affirmed. View "Bullen v. Mississippi" on Justia Law

Jelani Miles was convicted of shooting into a vehicle, aggravated assault, and second-degree murder. A circuit court sentenced Miles to five years for shooting into a vehicle, twenty years with five years suspended for aggravated assault, and life for second-degree murder, with all sentences to run consecutively. Miles appealed, and the Mississippi Supreme Court deflected his appeal to the Court of Appeals, which affirmed. The Supreme Court granted Miles’s petition for a writ of certiorari to review the remedy ordered by the Court of Appeals for the trial court’s imprecise and incomplete analysis under Batson v. Kentucky, 476 U.S. 79 (1986). The Supreme Court found the Court of Appeals applied the appropriate remedy by remanding for the trial court to conduct a hearing to complete the second and third steps of the Batson analysis for three challenged venirepersons. Therefore, the judgment of the circuit court's judgment was affirmed in part, and the case was remanded. View "Miles v. Mississippi" on Justia Law

In 2017, Shakeara Harris filed domestic violence charges against Joseph Eubanks. Eubanks was indicted for aggravated domestic violence in June 2017. He was later convicted of simple assault domestic violence in January 2020. Eubanks was sentenced to six months in the custody of the Mississippi Department of Corrections, with six months suspended and 364 days of unsupervised probation. He appealed, raising seven contentions as grounds for appeal. Finding no reversible error however, the Mississippi Supreme Court affirmed Eubanks' conviction. View "Eubanks v. Mississippi" on Justia Law

The Catholic Diocese of Jackson, Mississippi filed an interlocutory appeal of its motion to dismiss claims stemming from its termination of Arie Mattheus de Lange. The Diocese argued that, pursuant to the ecclesiastical abstention doctrine found in the First Amendment of the United States Constitution, Lange's employment action be dismissed for lack of subject-matter jurisdiction. The circuit court disagreed and determined that “the resolution of these claims will not require immersion into the faith, discipline and doctrine of the Catholic Church or the Code of Canon Law.” After careful review, the Mississippi Supreme Court concluded the circuit court erred and that the First Amendment demanded dismissal. View "Catholic Diocese of Jackson, Mississippi v. De Lange" on Justia Law

While driving a forklift at work, Lori Chandler was hit by another forklift and injured. She retained Turner & Associates to file a workers’ compensation claim. But Turner & Associates failed to file her claim within the statute of limitations. Adding to that, the firm’s case manager engaged in a year-and-a-half-long cover-up, which included false assurances of settlement negotiations, fake settlement offers, and a forged settlement letter purporting to be from Chandler’s former employer. Because of this professional negligence, Chandler filed a legal malpractice action. The only issue at trial was damages. The trial judge, sitting as fact-finder, concluded that Chandler had suffered a compensable work-related injury—an injury that caused her to lose her job and left her unemployed for nearly two years. Based on her hourly wage, the trial judge determined, had Turner & Associates timely filed Chandler’s workers’ compensation claim, Chandler could have reasonably recovered $50,000 in disability benefits. So the trial judge awarded her $50,000 in compensatory damages. The trial judge also awarded Chandler $100,000 in punitive damages against the case manager due to her egregious conduct. The Court of Appeals affirmed the punitive-damages award. But the court reversed and remanded the compensatory-damages award. Essentially, the Court of Appeals held that Chandler had failed to present sufficient medical evidence to support a $50,000 workers’ compensation claim. The Mississippi Supreme Court reversed the appellate court: "Were this a workers’ compensation case, we might agree with the Court of Appeals. But this is a legal malpractice case. And part of what Chandler lost, due to attorney negligence, was her ability to prove her work-related injury led to her temporary total disability. ... the Court of Appeals erred by applying exacting statutory requirements for a workers’ compensation claim to Chandler’s common-law legal malpractice claim." The Court reversed on the issue of compensatory damages and reinstated the trial judge’s $50,000 compensatory-damages award. Because this was the only issue for which Chandler sought certiorari review, it affirmed the remainder of the Court of Appeals’ decision, which affirmed the punitive-damages award but reversed and remanded the grant of partial summary judgment against attorney Angela Lairy in her individual capacity. View "Turner & Associates, PLLC, et al. v. Chandler" on Justia Law