Justia Mississippi Supreme Court Opinion Summaries

John Webb was convicted by jury on one count of fondling and three counts of sexual battery of two underage girls, one of whom was his live-in girlfriend’s daughter. On appeal, Webb asserted multiple evidentiary challenges against his convictions. After review, the Mississippi Supreme Court found the evidence “overwhelmingly favors the guilty verdicts” and affirmed. View "Webb v. Mississippi" on Justia Law

In 2012, United Healthcare of Mississippi (United) entered into provider agreements with Mississippi’s fourteen Community Mental Health Centers (CMHCs) to provide Medicaid services under the Division of Medicaid’s (DOM’s) managed care program. From 2012 until 2019, United paid the CMHCs an agreed upon amount for Medicaid services - 100 percent of the medicaid fee schedule rates. In July 2019, United unilaterally imposed a 5 percent rate cut, retroactive to January 1, 2019, and later demanded that the CMHCs refund 5 percent of all payments made from July 1, 2018, through December 31, 2018, all of which totaled more than $1 million. The CMCHs demanded that United immediately cease and desist from the 5 percent rate cut and recoupments. When United refused, the CMHCs filed a Complaint for Damages and Injunctive Relief, specifically requesting, inter alia, a preliminary injunction. United responded with a motion to compel arbitration and to stay the proceedings. After a two-day evidentiary hearing, the circuit court denied United’s motion to compel arbitration, granted the CMHCs’ request for injunctive relief, and issued a preliminary injunction. The limited issues presented to the Mississippi Supreme Court were whether the trial court properly enjoined United from imposing a 5 percent rate cut and whether the trial court erred by denying arbitration. After review, the Supreme Court affirmed the trial court’s decision to grant a preliminary injunction and to deny the motion to compel arbitration. View "United Healthcare of Mississippi Inc. et al. v. Mississippi's Community Mental Health Commissions, et al." on Justia Law

The Hinds County Circuit Court denied the motion of Weeks, Inc., to transfer venue to Madison County, even though neither Mississippi defendant (both corporations) had its principal place of business in Hinds County. Nor did any substantial alleged act or event causing the alleged injuries occur in Hinds County. The circuit court based its ruling on Weeks’s corporate filings with the Mississippi Secretary of State, which listed a Hinds County address as Weeks’s principal address. Affidavits and other documents submitted with Weeks’s motion to transfer venue showed this was not Weeks’s address; the address belonged to an outside certified public accountant who handled Weeks’s correspondence and filings with the Secretary of State. Weeks conducts no business from this location. Instead, it solely operates out of its Madison County location. Still, plaintiff Gregory Lewis, asked the Mississippi Supreme Court to hold that Weeks’s corporate filings were conclusive evidence of the corporation’s principal place of business. Lewis conceded, in his own words, that the “actual physical location” where Weeks conducted its business was in Madison County. The Supreme Court therefore concluded the circuit court abused its discretion by denying Weeks’s motion to transfer venue. Judgment was reversed and the matter remanded with instructions to transfer this case to the Madison County Circuit Court. View "Weeks, Inc. et al.. v. Lewis" on Justia Law

Holcomb, Dunbar, Watts, Best, Masters & Golmon, P.A. (“Holcomb Dunbar”), was the tenant and 400 South Lamar Mad Hatter Partners, LLC (“Mad Hatter”), was the successor landlord to the property at issue in this case. Mad Hatter sued Holcomb Dunbar for breach of the lease due to its failure to pay rent for the remaining eighteen months of a three-year lease. After discovery, Mad Hatter moved for summary judgment, which the trial court granted. Mad Hatter was awarded $133,900 in unpaid rent. The trial court also denied Holcomb Dunbar’s motion for partial summary judgment and motion to amend its counterclaim, while granting Mad Hatter’s motion to quash certain subpoenas. Holcomb Dunbar’s remaining counterclaims went to trial, and the jury found against it. Holcomb Dunbar appealed the trial court’s rulings on these four motions. The Court of Appeals affirmed the trial court’s judgment and the Mississippi Supreme Court granted certiorari. Finding no reversible error in the trial court's grant of summary judgment, the Supreme Court affirmed its judgment. View "Holcomb, Dunbar, Watts, Best, Masters & Golmon, P.A. v. 400 South Lamar Oxford Mad Hatter Partners, LLC, et al." on Justia Law

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