Justia Mississippi Supreme Court Opinion Summaries

Luke Beard executed a will on February 13, 1987. The will named Luke’s daughter, Diane Christmas, as executrix, and it left all of Luke’s property, including thirty-two acres of land, to his grandson, Antonio Christmas. Despite being named as executrix, Diane did not know about the will. Luke died on February 26, 2001. After Luke’s death, Diane and Antonio became estranged. Having no knowledge of the will, Diane petitioned to open an estate in 2002. Antonio was unaware of the estate proceeding. At some point in 2003, Antonio found Luke’s will in a closet in Luke’s house. Antonio did not tell his mother about the will and took no action regarding the will. In 2014, Diane filed a second petition to open an estate. As with the first petition, Antonio was unaware of the estate proceeding. According to Antonio, an order was later entered closing the estate and vesting title of the thirty-two acres of land to Diane. In 2017, Good Hope, Inc., entered the land and started to cut timber on the property. When Antonio attempted to stop them, he learned of the estate actions filed by Diane. Seventeen years after Luke’s death and fifteen years after he found the will, Antonio petitioned to probate Luke’s will. Diane contested the will and filed her objection to Antonio’s petition to probate. The matter went to trial before the chancery court. The issue this case presented for the Mississippi Supreme Court's review was what evidence was required to prove the execution of a will when both the testator and the subscribing witnesses are deceased. The Court found that in the absence of the testimony of at least one subscribing witness, a proponent of a will must prove the handwriting of the testator and at least two subscribing witnesses. Because there was proof of only one of the subscribing witnesses’ signatures, the chancellor did not err by dismissing the petition to probate the purported will. View "In the Matter of the Last Will and Testament of Luke Beard" on Justia Law

Victoria Leasy sued after she allegedly slipped and fell in her hotel room’s bathroom at Harlow’s Casino. The circuit court granted SW Gaming LLC d/b/a Harlow’s Casino's motion to dismiss, and on appeal, the Court of Appeals reversed the judgment of the circuit court and remanded the case. Finding that the Court of Appeals reweighed the evidence and substituted its own findings for those of the circuit court, the Mississippi Supreme Court reversed the Court of Appeals. The Supreme Court reinstated and affirmed the judgment of the circuit court, and reaffirmed the controlling abuse-of-discretion standard of review in such cases. View "Leasy v. SW Gaming, LLC d/b/a Harlow's Casino" on Justia Law

Claiborne County Hospital (CCH) sought summary judgment against Julius Truitt on his medical-negligence claim. CCH claimed Truitt failed to designate a medical expert. Truitt responded to CCH’s motion that a genuine issue of material fact existed, and that he was exempt from producing sworn expert testimony under the layman’s exception allowing lay testimony despite the general rule requiring medical expert testimony in medical-negligence cases. The Mississippi Supreme Court found that as a matter of law, the trial court erred by denying CCH’s motion for summary judgment. The Supreme Court found CCH met its summary-judgment burden by showing that Truitt failed to produce sworn expert testimony establishing a prima facie case of medical negligence. The trial court's judgment was reversed and the matter remanded for further proceedings. View "Claiborne County Hospital v. Truitt" on Justia Law

Courtney Rainey was indicted on two counts: (I) voter fraud; and (II) witness intimidation. The jury found Rainey guilty of Count II but could not decide on Count I, and the circuit court declared a mistrial as to Count I. On the conviction for Count II, Rainey was sentenced to serve fifteen years with three years suspended and five years’ probation, together with court costs and fees. The circuit court denied Rainey’s post-trial motions. A divided Court of Appeals reversed and rendered Rainey’s conviction and sentence, finding insufficient evidence to support conviction under Count II. The State filed a petition for writ of certiorari arguing that the Court of Appeals erred in finding insufficient evidence relating to Rainey’s conviction for witness intimidation, and that Rainey’s sentence did not amount to cruel and unusual punishment under the Eighth Amendment. After review, the Mississippi Supreme Court reversed the Court of Appeals and reinstated and affirmed the circuit court's judgment. View "Rainey v. Mississippi" on Justia Law

This appeal presented a question of first impression in Mississippi as to whether short-term rentals of private homes through online services such as Airbnb, VRBO, and HomeAway were residential uses of property for the purposes of a restrictive covenant. The trial court’s finding that Clyde Esplin’s use of his property was residential and that short-term rentals were allowed under the covenants was affirmed as was the trial court's finding that the amended bylaws restricting property rentals were invalid. View "Lake Serene Property Owners Association, Inc. v. Esplin" on Justia Law

The Workers’ Compensation Commission and an Administrative Judge (AJ) had ordered Gamma Healthcare and Employers Insurance Company of Wausau (Employer/Carrier) to replace Sharon Grantham’s septic and HVAC systems and to pay for insurance on a handicapped-accessible van. The Commission, sua sponte, issued a separate order sanctioning the Employer/Carrier for causing an unnecessary delay by appealing the AJ’s order to the full Commission without reasonable grounds. The Employer/Carrier appealed. While this case was pending before the Court of Appeals, Sharon Grantham died. Thereafter, the Court of Appeals dismissed the case as moot. The Court of Appeals applied the general rule followed by federal courts by vacating the outstanding Commission and AJ orders. The appeals court reversed and rendered the Commission’s sanctions order against the Employer/Carrier, determining that the Commission had abused its discretion by its imposition of the sanction, reasoning that the Employer/Carrier had a reasonable legal argument for its appeal. Grantham’s estate filed a petition for a writ of certiorari, which the Mississippi Supreme Court granted. The Supreme Court concluded that in light of Grantham’s untimely death and the concession by her estate, it agreed with the Court of Appeals that this case was moot. "However, the main issue is not whether the case is moot. Rather it is whether the Court of Appeals erred by vacating the Commission’s and the AJ’s valid orders to replace the septic and HVAC systems in a case that became moot on appeal due to circumstances beyond the control of the parties. Additionally, did the court err by following federal vacatur law instead of existing Mississippi law?" These were issues of first impression. the Supreme Court found that the Court of Appeals did not err and that the federal vacatur rule was appropriate. The Commission’s orders were vacated properly. Furthermore, the Supreme Court affirmed the Court of Appeals’ reversing and rendering of the Commission’s sanctions award. View "Gamma Healthcare Inc., et al. v. Estate of Sharon Burrell Grantham" on Justia Law

This appeal stemmed from damages that Pine Belt Oil Co. (Pine Belt) incurred for the remediation of a September 2008 gasoline leak that originated on property Walter and Tammy Cooley (the Cooleys) had sold to Pine Belt four months prior to discovery of the leak. In 2009, the Mississippi Department of Environmental Quality (MDEQ) issued an administrative order demanding that Pine Belt, the owners of Pine Belt, Robert and Melissa Morgan, and the Cooleys pay remediation costs, including future costs, for the properties afflicted by the gasoline leak. Since October 2008, Pine Belt maintained that the Cooleys were responsible for the gasoline leak, not Pine Belt. After initially refusing to pay the remediation costs, Pine Belt did begin paying them in July 2009. In April 2016, six years and nine months after its first remediation payment, Pine Belt filed a complaint seeking indemnification from the Cooleys for Pine Belt’s past and future expenses incurred due to its remediation damage caused by the gasoline leak. The Cooleys moved for summary judgment, arguing that the claim was barred by the statute of limitations. The trial judge denied the summary judgment motion. The Cooleys then filed a petition for interlocutory appeal, arguing that the statute of limitations barred Pine Belt’s implied indemnity claim. The Cooleys argued alternatively that Pine Belt could not prove that it did not actively participate in the underlying wrong, i.e., the gasoline leak. The Mississippi Supreme Court held that the applicable three-year statute of limitations ran on Pine Belt’s claim on March 5, 2012. Pine Belt’s claim was thus time barred, and all other arguments were moot. View "Cooley v. Pine Belt Oil Co., Inc." on Justia Law

Janarious Jones was indicted by grand jury for for first-degree murder. A jury would ultimately convict him of manslaughter, for which he was sentenced to prison for twenty years, with five years suspended. After denial of his post-trial motions, Jones appealed, arguing: (1) the circuit court erred by not requiring the jury to specify which theory of manslaughter the jury used to convict Jones; (2) the State presented insufficient evidence to support a heat-of-passion manslaughter conviction; and (3) the circuit court committed reversible error when it dispersed the jury for lunch. Finding no error, the Mississippi Supreme Court affirmed Jones’s conviction and sentence. View "Jones v. Mississippi" on Justia Law

Bobby Batiste was convicted of capital murder for which he was sentenced to death. The Mississippi Supreme Court later granted Batiste the right to file a petition for post-conviction relief (PCR) ("Batiste II") because the Court determined he was entitled to a hearing regarding alleged communications between bailiffs and/or others and members of the jury. During the hearings on Batiste’s PCR petition, a motion requesting the recusal of the trial judge was made, arguing that the judge's own memory of an alleged conversation with a juror could be relied on in witness-credibility determinations while evaluating the merits underlying the PCR petition. This motion was denied and, ultimately, the PCR petition was denied. Batiste appealed both the denial of the motion to recuse as well as the denial of the PCR petition on the merits. In September 2020, having found that evidentiary questions remained relating to the recusal issue, the Supreme Court declined to address the merits of the PCR petition and remanded the case (Batiste III). On November 20, 2020, the circuit court held a hearing pursuant to the Supreme Court's directions for remand in Batiste III “for the limited purpose of allowing the trial judge to hear such evidence as is necessary to allow him to clear up any ambiguity and to determine if the alleged conversation did, in fact, take place ‘during trial,’ and, if it did, whether the conversation is alleged to have occurred on or off the record.” After that hearing, the circuit court found that the alleged discussion between the court and the witness took place after the guilt and the Supreme Court affirmed the circuit court’s denial of Batiste’s motion to recuse and his PCR petition. View "Batiste v. Mississippi" on Justia Law

Jabrien Williams was twenty-two years old when he convinced fourteen-year-old JR to unlock the window of an unoccupied bedroom of her family’s ground-floor apartment. Once inside, Williams had sex with the JR. Days later, Williams texted JR, attempting to have sex with her again. Soon after, JR’s stepfather discovered the messages on the family’s iPod. JR told her stepfather that Williams sent the messages to her. She then informed her mother she had sex with Williams in their apartment. Williams was indicted on one count of sexual battery. Before trial, Williams’s counsel disclosed that one of Williams’s defense theories would be that someone else—namely, Williams’s younger brother, who went to school with JR—sent the text messages from Williams’s phone. But at trial, Williams employed a different defense, steadfastly denying that the phone number used to send JR the messages was his. His younger brother also testified the number was not Williams’s. The State ran the phone number through the Madison County Detention Center logs. After the State rested, it learned this exact phone number was listed by Williams as his contact number when he received an ankle monitor for an unrelated crime. Realizing Williams had been wearing the GPS monitor during the relevant time frame, the State inquired further and learned GPS coordinates placed Williams at JR’s apartment the night she reported he had sex with her. Over Williams’s objection, the judge permitted the State to introduce this evidence during its rebuttal. On appeal of his conviction, Williams challenged several evidentiary rulings, significantly the admission of the State's rebuttal evidence. The Mississippi Supreme Court found no abuse of discretion in the trial court's ruling, and affirmed. View "Williams v. Mississippi" on Justia Law