Justia Mississippi Supreme Court Opinion Summaries

Brandon J. Barnett was convicted of selling methamphetamine after a confidential informant, Kimberly Dido, arranged a controlled buy with him. Dido, who had previously bought drugs from Barnett, was working with the Jones County Sheriff’s Department in exchange for having her charges dropped. During the controlled buy, Dido was fitted with a hidden camera and given marked bills to purchase drugs from Barnett. The substance obtained was later confirmed to be 3.01 grams of methamphetamine.At trial, the forensic analyst who tested the substance did not testify. Instead, a different analyst, Charlotte Cothern, testified as a technical reviewer, stating that she agreed with the test results. Barnett’s counsel highlighted that Cothern did not personally test the substance. The trial court granted a jury instruction (Instruction S-3A) stating that it was permissible for a technical reviewer to testify in place of the primary analyst, which Barnett objected to, arguing it improperly commented on the weight of the evidence.The Mississippi Supreme Court reviewed the case and found that the trial court erred in giving Instruction S-3A. The court held that the instruction improperly commented on the weight and credibility of the technical reviewer’s testimony, which are matters for the jury to decide. The court emphasized that while the admissibility of the testimony is a legal question for the judge, the weight and credibility are exclusively for the jury. Consequently, the court reversed Barnett’s conviction and remanded the case for a new trial. View "Barnett v. State of Mississippi" on Justia Law

Olympia Williams was driving a Chrysler 200 on a public roadway with Mary Thomas as a passenger when they were struck by an ATV operated by Patricia Cole. The Chrysler 200, owned by Alonzo Johnson, was insured through Mississippi Farm Bureau Casualty Insurance Company (Farm Bureau) and included uninsured motorist coverage. Cole had no applicable insurance. Farm Bureau sought a declaratory judgment that it owed no uninsured motorist benefits, citing a policy exclusion for vehicles designed mainly for off-road use and not capable of being licensed for public roads.The Issaquena County Circuit Court granted summary judgment in favor of Farm Bureau, agreeing that the policy's exclusion applied to the ATV involved in the collision. Williams, Thomas, and Johnson argued that they were entitled to the full amount of the policy’s uninsured motorist coverage and that the exclusion unlawfully restricted coverage required by Mississippi’s Uninsured Motorist Act. They appealed the decision.The Supreme Court of Mississippi reviewed the case de novo and affirmed the circuit court's judgment. The court held that the policy's language was clear and unambiguous, excluding ATVs from the definition of "uninsured motor vehicle." The court also found that the exclusion did not unlawfully restrict or reduce coverage mandated by Mississippi’s Uninsured Motorist Act. The court concluded that the ATV operated by Cole did not qualify as an uninsured motor vehicle under the policy, and thus, Farm Bureau was not obligated to provide uninsured motorist benefits. View "Williams v. Mississippi Farm Bureau Casualty Insurance Company" on Justia Law

In this case, the appellant, X.G.C., appealed the termination of his parental rights over his child, V.I.C. The child was born in December 2019 and suffered multiple injuries while in the care of her parents, including a subdural hematoma and a fractured arm. The Jackson County Department of Child Protection Services (JCCPS) took custody of the child after determining that the injuries were consistent with abuse. Despite efforts to reunify the family, including a service plan and a ninety-day trial placement, the child sustained further injuries, leading to the termination of the father's parental rights.The Jackson County Youth Court initially placed the child in JCCPS custody and ordered efforts towards reunification. However, after the child sustained additional injuries during the trial placement with her father, the court changed the permanency plan to termination of parental rights. The court conducted multiple hearings and found that JCCPS had made reasonable efforts to assist the father in complying with the service plan, but he had failed to provide a safe environment for the child.The Supreme Court of Mississippi reviewed the case and affirmed the youth court's decision. The court found that the statutory requirements for termination under Mississippi Code Section 93-15-115 were met, including the adjudication of the child as abused, the child's placement in JCCPS custody for over six months, and the father's failure to comply with the service plan. The court also determined that termination was appropriate under Section 93-15-119, as the father's conduct demonstrated a substantial risk to the child's safety and welfare. The court concluded that the youth court's findings were supported by substantial evidence and that the termination of parental rights was in the best interest of the child. View "X.G.C. v. Jackson County Department of Child Protection Services" on Justia Law

Clover Boykin filed a lawsuit against Greenwood Leflore Hospital (GLH) under 42 U.S.C. § 1983, alleging that GLH intentionally withheld her medical records, preventing her from filing a medical malpractice suit. Boykin claimed that GLH's actions violated her constitutional right of access to the courts. GLH responded with a motion to dismiss, arguing that Boykin's claims failed as a matter of law, the employee was immune from suit, GLH was never served, and the suit was time-barred.The Leflore County Circuit Court denied GLH's motion to dismiss and granted Boykin additional time to serve GLH. GLH then sought an interlocutory appeal, which the Supreme Court of Mississippi granted. Boykin did not file a brief in response to the appeal.The Supreme Court of Mississippi accepted Boykin's failure to file a brief as a confession of error and found that Boykin's claims failed as a matter of law. The court held that HIPAA does not provide a private right of action and that Boykin could not use § 1983 to enforce a federal statute that does not give her an individual right. The court reversed the trial judge's denial of the motion to dismiss and rendered judgment in favor of GLH. View "Greenwood Leflore Hospital v. Boykin" on Justia Law

Judge Carlos Moore, a municipal court judge for the cities of Clarksdale and Grenada, faced allegations of misconduct related to his social media posts and public comments. The Mississippi Commission on Judicial Performance (the Commission) claimed that Moore's actions violated the Mississippi Constitution, the Code of Judicial Conduct, and a Memorandum of Understanding (MOU) between the Commission and Moore. The Commission's allegations stemmed from Moore's social media activity in 2021 and 2022, where he posted content that could be perceived as advertising his law practice and making racially charged comments.The Commission had previously warned Moore in 2019 about posting information on social media regarding cases he heard in court. In 2020, Moore and the Commission entered into an MOU, where Moore agreed to limit his social media posts to court-related information and not use his judicial title for personal or political purposes. Despite this agreement, Moore continued to post under the name "Judge Carlos Moore" and made public comments that the Commission deemed inappropriate.The Commission filed a Formal Complaint against Moore in July 2022, alleging violations of the Mississippi Constitution and the Code of Judicial Conduct. Moore did not respond to the complaint or participate in the Commission's proceedings. The Commission recommended Moore's removal from office, a six-year suspension, and a $5,000 fine.The Supreme Court of Mississippi reviewed the case and found that Moore's actions constituted willful misconduct and were prejudicial to the administration of justice. The Court held that Moore's comments on social media and television violated the judicial-conduct canons and the MOU. The Court ordered Moore's removal from the bench, a $3,000 fine, and assessed all costs. The Court emphasized that Moore's actions undermined public confidence in the judiciary and warranted a harsh sanction. View "Mississippi Commission on Judicial Performance v. Moore" on Justia Law

Jane's three young daughters were taken into custody by the Mississippi Department of Child Protection Services (CPS) due to unsafe living conditions and neglect. Jane had left her daughters with her disabled mother in a cramped, unsupervised apartment. CPS developed a service plan for Jane to regain custody, which included obtaining stable housing, employment, and transportation. Despite completing parenting classes and getting clean from drugs, Jane failed to comply with the other requirements. She did not secure stable housing or employment and did not regularly visit her daughters. Consequently, CPS petitioned to terminate her parental rights.The Monroe County Chancery Court held a termination hearing where CPS workers testified about Jane's noncompliance with the service plan and the unsafe conditions that led to the removal of her daughters. Jane testified about her efforts to get clean and find employment but admitted to various failures. The court-appointed Guardian Ad Litem recommended terminating Jane's parental rights, citing her unwillingness to provide for her daughters' basic needs. The chancellor found clear and convincing evidence supporting the termination based on statutory grounds, including abandonment, unwillingness to provide necessary care, failure to exercise reasonable visitation, and substantial erosion of the parent-child relationship.The Supreme Court of Mississippi reviewed the case and affirmed the chancellor's decision. The court held that substantial evidence supported the termination of Jane's parental rights, emphasizing that her lack of effort to care for and visit her daughters, rather than her lack of money, was the reason for the termination. The court found that the termination was in the best interest of the children to ensure a permanent and stable future. View "J.J.B. v. Monroe County Department of Child Protection Services" on Justia Law

Chester “Chet” Lake contested the probate of his mother’s will, which his sister Mary Chesnutt had filed. Lake doubted the will’s validity, claiming undue influence, and requested a jury trial to determine the issue of devisavit vel non. The Madison County Chancery Court entered a scheduling order but did not specify whether the trial would be a bench or jury trial. After the discovery and motions deadlines passed, Lake filed a Notice of Jury Trial. Chesnutt moved to strike the notice, arguing that Lake had waived his right to a jury trial by participating in pretrial proceedings and that the notice was untimely.The Madison County Chancery Court granted Chesnutt’s motion to strike, finding that Lake had waived his right to a jury trial by agreeing to the scheduling order and that his notice was untimely. Lake appealed this decision.The Supreme Court of Mississippi reviewed the case and held that Lake had not waived his right to a jury trial. The court found that under Mississippi Code Section 91-7-19, Lake was entitled to a jury trial upon request before any hearing on the issue of devisavit vel non. The court determined that the entry of the scheduling order did not constitute a hearing on the matter and that Lake’s notice, filed thirty-two days before the trial date, was timely. The court reversed the chancery court’s decision and remanded the case for further proceedings consistent with its opinion. View "In the Matter of the Estate of Lake v. Chesnutt" on Justia Law

Donald Quinn was indicted for the sexual battery of his seventeen-year-old niece, resulting in her pregnancy. The indictment was amended to reflect the crime occurred between July 1, 2015, and May 25, 2016. Pretrial motions included the exclusion of hearsay statements from the victim and her mother, who were unavailable to testify. The trial court allowed limited testimony from Detective Neal and admitted DNA evidence linking Quinn to the child.The Hinds County Circuit Court convicted Quinn, sentencing him to twenty years, with ten years suspended. Quinn's motion for judgment notwithstanding the verdict or a new trial was denied. On appeal, the Court of Appeals reversed the conviction, citing insufficient proof of venue and potential issues with witness testimony and evidence admission.The Supreme Court of Mississippi reviewed the case on certiorari. The court found that the trial court did not err in its rulings. It held that the State sufficiently proved venue through Detective Neal's unobjected-to testimony, which established the crime occurred in Hinds County. The court also found no error in admitting Dr. Schiro's DNA testimony, as he was sufficiently involved in the analysis and report. The amendment to the indictment was deemed proper, as it did not prejudice Quinn's defense. Carolyn Smith's testimony was allowed despite late disclosure, as it did not result in manifest injustice. The court also ruled that the trial court properly handled the State's closing argument and the use of birth certificates to refresh Smith's memory.The Supreme Court of Mississippi reversed the Court of Appeals' decision and reinstated and affirmed the Hinds County Circuit Court's judgment. View "Quinn v. State" on Justia Law

Hemphill Construction Company, Inc. (Hemphill) entered into a contract with the City of Jackson and subsequently subcontracted Interstate Carbonic Enterprises (ICE) for a project. Gay Lynn Harris, Jr., an owner and officer of ICE, was severely injured while working on the project in September 2020. Harris sought workers’ compensation benefits from Hemphill, but an Administrative Judge (AJ) ruled that Harris was not entitled to these benefits because he had voluntarily opted out of ICE’s workers’ compensation insurance coverage. Neither party appealed the AJ’s decision.In March 2022, Harris filed a negligence complaint against Hemphill in the Circuit Court of the First Judicial District of Hinds County. Hemphill moved to dismiss the complaint, claiming tort immunity under the exclusive remedy provision of the Mississippi Workers’ Compensation Act (MWCA). The trial court agreed and granted Hemphill’s motion to dismiss. Harris appealed, arguing that tort immunity did not apply and that judicial estoppel should apply. Hemphill contended that Harris had not exhausted his administrative remedies.The Supreme Court of Mississippi reviewed the case and found that Harris was not required to exhaust his administrative remedies before filing his negligence suit. The court held that Hemphill was entitled to tort immunity because it had contractually required ICE to obtain workers’ compensation insurance for its employees, thus satisfying the statutory requirement to secure payment under the MWCA. The court affirmed the trial court’s decision to dismiss Harris’s negligence claim against Hemphill. View "Harris v. Hemphill Construction Company, Inc." on Justia Law

The National Collegiate Athletic Association (NCAA) conducted an investigation into the University of Mississippi's football program, which included allegations against Barney Farrar, an assistant athletics director. The NCAA found Farrar guilty of multiple recruiting violations and issued a five-year show-cause order, restricting his employment in recruiting roles at NCAA member institutions. Farrar appealed the decision, but the NCAA's Infractions Appeals Committee upheld the findings and penalties.Farrar then filed a lawsuit in the Circuit Court of Lafayette County, alleging negligence, denial of a fair hearing, malicious interference with employment, denial of due process under the Mississippi Constitution, and usurpation of judicial function. The trial court granted summary judgment in favor of the NCAA on all claims except for malicious interference with employment and denial of due process. The NCAA petitioned for an interlocutory appeal on these two issues.The Supreme Court of Mississippi reviewed the case and applied a de novo standard of review. The court held that the NCAA is not a state actor and thus not subject to due process requirements under the Mississippi Constitution. The court also found that Farrar failed to provide evidence of malice necessary to support his claim of malicious interference with employment. Consequently, the court reversed the trial court's denial of summary judgment and rendered judgment in favor of the NCAA. View "National Collegiate Athletic Association v. Farrar" on Justia Law