Justia Mississippi Supreme Court Opinion Summaries

Lester Randle died in 2009, survived by his wife and son, Dorothy and Raymond. Lester had previously been married to Ruthie Randle. Two children were born of that marriage: Tumika and Sylvester, the Appellants. Ruthie and Lester divorced in 1977 when the children were very young. Lester died intestate. On May 7, 2018, Dorothy filed a petition for grant of letters of administration in which she noted that Lester’s “estate consist[ed] of no real property but ha[d] a potential claim for unliquidated damages arising out of” Lester’s death. The petition acknowledged the Appellants, as well as Dorothy and Raymond, as Lester’s heirs at law. Dorothy was appointed administrator on July 12, 2018. On November 19, 2018, Dorothy filed a petition for a determination of heirship, now asserting that the estate consisted of a claim for benefits against the manufacturer of Granuflow/Natural Lyte in the amount of $67,500.25 arising from Lester’s use of the prescription drug. The petition further claimed that the Appellants were “not heirs at law of Lester Randle and [were] not entitled to any of the settlement proceeds,” but rather they “were born to a married man, putative father,” and Ruthie. A summons by publication was submitted in the newspaper to any unknown heirs. The Court of Appeals affirmed a chancellor's adjudication that Dorothy and Raymond were Lester's only heirs at law. The issues this case presented for the Mississippi Supreme Court's review were: (1) whether the chancery court and the Court of Appeals incorrectly considered the settlement proceeds from a wrongful-death claim as an asset of the estate; and (2) whether the chancery court and the Court of Appeals incorrectly considered the petition to determine heirs under Mississippi Code Sections 91-1-1 to -31 (Rev. 2021) instead of a determination of wrongful-death beneficiaries under Mississippi Code Section 11-7-13 (Rev. 2019). The Supreme Court reversed the judgments of the Court of Appeals and chancery court and remanded this case to the chancery court to determine the wrongful-death beneficiaries of Lester under Section 11-7-13. View "Randle v. Randle" on Justia Law

A probation officer improperly induced L.J. Green III to give a statement that led to the discovery of the linchpin evidence used against Green at his robbery trial. While the trial judge suppressed Green’s statement, the judge still admitted evidence that Green possessed the victim’s car keys - evidence wholly derived from Green’s excluded statement. This evidence was admitted over Green’s objection; a jury convicted Green. On appeal, both Green and the State agreed the trial judge wrongly admitted the tainted evidence. Though the State argued the error was harmless, the Mississippi Supreme Court concluded the evidence strongly contributed to Green’s guilty verdicts. “So its admission was not harmless error.” Judgment was therefore reversed and the matter remanded for a new trial. View "Green v. Mississippi" on Justia Law

Ladarius Garrett was convicted by jury of burglary of a hotel room. He claimed his convictions as not supported by sufficient evidence, and that the jury’s verdict was contrary to the overwhelming weight of the evidence. Finding no merit to either claim, the Mississippi Supreme Court affirmed Garrett’s conviction. View "Garrett v. Mississippi" on Justia Law

Byram Café Group, LLC (BCG), moved for summary judgment against Eddie and Teresa Tucker in a premises-liability action arising from Eddie’s slip-and-fall accident. BCG sought judgment as a matter of law based on a lack of evidence supporting any of the elements of a slip-and-fall case. In response, the Tuckers argued that genuine issues of material fact existed as to dangerous conditions that may have caused Eddie’s fall. The circuit court denied BCG’s summary judgment motion. BCG sought interlocutory appeal, which the Mississippi Supreme Court granted. The issue the appeal presented was whether the Tuckers could survive a motion for summary judgment without producing evidence that a dangerous condition existed, that BCG caused the hypothetical dangerous condition, and that BCG knew or should have known about the dangerous condition. As a matter of law, the Supreme Court found the circuit court erred by denying BCG’s motion for summary judgment. Accordingly, the Court reversed and remanded the circuit court’s order. View "Byram Cafe Group, LLC v. Tucker" on Justia Law

The Mississippi Supreme Court granted Omar Humphrey’s petition for certiorari review of a Court of Appeals decision that dismissed his case. Humphrey’s complaint alleged that neither Steve Holts, police chief of Senatobia, nor John Champion, district attorney for the Seventeenth Circuit Court District, had responded to his letters requesting evidence and documents that related to his conviction made pursuant to the Public Records Act. Humphrey’s complaint alleged the same basis for his claims against both Holts and Champion and made very little, if any, distinction between the two other than referencing the individual letters sent to each defendant. The Court of Appeals dismissed the case for want of an appealable judgment. The Mississippi Supreme Court concluded the was, in fact, a final, appealable judgment and that the Court of Appeals should have decided Humphrey’s case on the merits. View "Humphrey v. Holts, et al." on Justia Law

Phillip and Anna Kennedy contracted with DIMA Homes, Inc., to build a house on property they owned in Marion County, Mississippi. The Kennedys failed to pay DIMA, and DIMA obtained a judgment, which it properly enrolled, creating a judgment lien on the property. The Kennedys then failed to pay property taxes, and in 2016, the land was sold at a tax sale to ACC Tax Sales Property, LLC. HL&C Marion, LCC, obtained the property from ACC. DIMA did not receive notice of the tax sale. In 2019, HL&C filed suit to quiet title. The chancery court ruled that the failure to give written notice of the sale to DIMA resulted in an extension of the two-year redemption period and set aside the tax sale. The Court of Appeals affirmed. The Mississippi Supreme Court granted certiorari and reversed the judgments of the Court of Appeals and the chancellor, and holding that no legal authority required notice of the tax sale to have been given to DIMA. Accordingly, judgment is rendered in favor of HL&C Marion. View "HL&C Marion, LLC v. DIMA Homes, Inc." on Justia Law

A grand jury indicted Dwayne Wilson on one count of aggravated assault. The indictment charges that Wilson “unlawfully, willfully, purposely and feloniously attempt[ed] to cause or knowingly caused bodily injury to . . . Stacy Pierce[] by striking him multiple times in the ribs and mouth with a bat, a means likely to produce death or serious bodily harm[.]” Wilson pled not guilty, but he was ultimately convicted on that charge when his first trial ended in a mistrial. On appeal, Wilson contended the second trial violated his constitutional protection against double jeopardy. Additionally, Wilson claimed the verdict was against the overwhelming weight of the evidence. The Mississippi Supreme Court concluded that although the protections against double jeopardy had attached, the trial court did not abuse its discretion by finding manifest necessity to grant a mistrial. Further, the Court found the verdict in the second trial was not against the overwhelming weight of the evidence presented. Accordingly, judgment and conviction were affirmed. View "Wilson v. Mississippi" on Justia Law

Two Mississippi school districts disputed whether the disbursement of past revenues generated from sixteenth section land located in townships shared by the two school districts and received by one, should have been shared by the other. The Mississippi Supreme Court found that the applicable governing statutes placed the burden on the noncustodial school district to provide student lists to the custodial school district, and made it unlawful for the custodial school district to pay over “until the lists . . . have been made.” Because the one-year period delineated in Section 29-3-119(4) did not place a time limit on litigation but rather a time limit on when a noncustodial district could make a claim with a custodial district, it was not a statute of limitations. Commensurate with its duty to presume the validity of legislative enactments, the Supreme Court reversed the judgment of the trial court and render judgment in favor of the custodial district, Wayne County School District, because Quitman School District’s claims were outside the prescribed time limit in the statute. View "Wayne County School District v. Quitman School District" on Justia Law

Soon after the Mississippi Supreme Court appointed counsel to represent death-row inmate Alberto Garcia in post-conviction proceedings before it challenging his death sentence, the Attorney General preemptively filed in the trial court a “Motion for Notice of and an Opportunity to Be Heard on Requests for Litigation Expenses.” Relying on Mississippi Rule of Appellate Procedure 22(c)(3), the Attorney General asserted her office was entitled to notice and an opportunity to be heard on Garcia’s requests for litigation expenses. Even though Garcia’s counsel had made no such request, the trial court granted the motion. The Supreme Court vacated this ruling: "Under Rule 22(c)(3), the Attorney General is not entitled to notice and an opportunity to be heard on a request for litigation expenses that was never made—and will never be made—because Garcia’s appointed attorneys are not compensated and reimbursed through court-approved expenses but rather through their state employer. ... So the Attorney General’s request was not only premature; it was inapplicable. Thus, the trial court lacked authority to grant the Attorney General’s motion." View "Garcia v. Mississippi" on Justia Law

The issue this appeal presented stemmed from a circuit court's grant of summary judgment to First American Title Company (First American) and its grant of a declaratory udgment to Pinehaven Group, LLC (Pinehaven), against Singing River Health System Ambulatory Services (AS). Singing River Health System (SRHS) informed AS that its real estate purchase from Pinehaven ten years before was void for lack of ratification by the Jackson County Board of Supervisors (the board). AS sought to void the purchase and to recover from Pinehaven and First American. The circuit court held that AS’s purchase from Pinehaven was valid and enforceable. Finding that no factual dispute that the contract was valid and enforceable existed, the Mississippi Supreme Court declined to address the other issues presented on appeal that were based on the alleged ratification requirement. "AS properly considered, approved, and executed the contract for its purchase of the Pinehaven property. As such, we affirm the circuit court’s decision that lack of ratification did not render the Pinehaven purchase void." View "SRHS Ambulatory Services, Inc. v. Pinehaven Group, LLC, et al." on Justia Law