Justia Mississippi Supreme Court Opinion Summaries

Twelve Medicaid-participating hospitals (“Hospitals”) challenged the Department of Medicaid’s (“DOM’s”) recalculation of their Medicaid outpatient rates for fiscal year 2001. The chancery court affirmed the opinion of the DOM, finding that “DOM interpreted its own regulation – the State Plan, which is its contract with the federal government and which it is required to follow to receive federal funds to require Medicaid to calculate the cost to charge ratio by using Medicare Methodology, which at that time was using a blended rate.” The Mississippi Supreme Court found the plain language of Attachment 4.19-B of the State Plan provided a cost-to-charge-ratio formula for calculating outpatient rates. Laboratory and radiology charges were to be excluded from this formula, because they were reimbursed on a fee-for-service basis. DOM’s inclusion of radiology and laboratory services in the charges and substitution of costs with Medicare blended payment amounts was a clear violation of the State Plan. Therefore, the Court reversed the judgments of DOM and the chancery court. Consistent with its opinion, the Court remanded and ordered the Executive Director of DOM to recalculate the Hospitals’ cost-to-charge ratio using the Hospital’s submitted costs in their cost reports, excluding laboratory and radiology services, and reimbursing the Hospitals the appropriate amounts determined by using the State Plan. View "Crossgates River Oaks Hospital v. Mississippi Division of Medicaid" on Justia Law

First Presbyterian Church PCUSA of Starkville, Mississippi, (“FPC”) sought declaratory relief, a temporary restraining order, and injunctive relief against the Presbytery of St. Andrew Presbyterian Church U.S.A., Inc. (“Presbytery”), after the Presbytery claimed FPC’s property was held in trust for the Presbyterian Church in the United States of America (“PCUSA”). FPC has transitioned into and out of multiple Presbyterian denominations, including the Old School Presbyterian Church; the Presbyterian Church, Confederate States of America; and the Presbyterian Church in the United States (“PCUS”). In 1983, the PCUS merged with another Presbyterian denomination to create the Presbyterian Church in the United States of America (“PCUSA”). FPC has been affiliated with the PCUSA since its inception. FPC claimed that, although it was affiliated with several different Presbyterian denominations, it existed as an “independent, unincorporated religious association from its founding until 2003.” Following its incorporation, FPC conveyed to the corporation its main property and facility in Starkville. The titleholder of record was then identified as FPC’s corporate entity. Any property duly transferred to the corporation remains held by and titled in the name of First Presbyterian Church, Starkville, Mississippi. Prior to 1982, no official documents of the PCUS included trust language. After the PCUSA was formed, the Book of Order contained a trust clause, and local churches then were required to “obtain permission before selling, mortgaging, or otherwise encumbering the property of that particular church.” Because this new trust clause was a departure from prior practice, the PCUSA’s constitution allowed for a “property exception.” Due to increasing disagreement with the PCUSA, FPC voted to cease monetary contributions to the Presbytery and look at the possibility of joining another Presbyterian denomination. In response to schism in the membership of FPC, the Presbytery notified FPC that it had appointed a Presbytery committee, called an Administrative Commission, to “inquire into and settle difficulties” at FPC. FPC’s session passed a resolution authorizing the filing of a legal action to determine the property rights of FPC, the Presbytery, and the PCUSA. FPC sought a declaratory judgment recognizing FPC’s exclusive ownership of all property held by it or in its name, free of any trust claimed by the PCUSA. FPC also requested a temporary restraining order prohibiting the Presbytery from taking control or possession of FPC’s property or from interfering with FPC’s property ownership. The chancery court granted summary judgment in favor of FPC, finding no evidence of any trust, express or implied. After review, the Mississippi Supreme Court agreed and affirmed the finding of the chancery court. View "Presbytery of St. Andrew, Presbyterian Church U.S.A., Inc. v. First Presbyterian Church PCUSA of Starkville" on Justia Law

Plaintiffs John Davis and Shad Denson filed a complaint seeking declaratory and injunctive relief against the City of Jackson, Mississippi (“City”). The plaintiffs, both taxicab drivers, sought: (1) a declaratory judgment that the City’s taxicab ordinances violate the Mississippi Constitution; and (2) an injunction to prevent the City from denying the plaintiffs a Certificate of Public Necessity for their failure to comply with the City’s ordinances. The City filed a motion to dismiss the plaintiffs’ complaint for lack of subject-matter jurisdiction, citing Mississippi Code Section 11-51-75 (Rev. 2012), which required a bill of exceptions to be filed and transferred to circuit court when the complaining party was aggrieved by a discretionary action of a municipal governing authority. The chancery court granted the City’s motion to dismiss, finding it lacked jurisdiction to consider the case. The plaintiffs appealed. The Mississippi Supreme Court found the dismissal for lack of jurisdiction was proper, but for a different reason: plaintiffs lacked standing to challenge the constitutionality of the City’s taxi ordinances because they failed to file or complete the required application to start a taxicab company in Jackson. View "Davis v. City of Jackson" on Justia Law

On April 19, 2011, the vehicles driven by Victor May and Kenneth Austin collided at the intersection of Northside Drive and Hanging Moss Road in Jackson, Mississippi. Claiming that the wreck produced injuries to his neck, lower back, and right shoulder, May filed suit seeking damages for Austin’s alleged negligence in causing the accident. Shortly after May filed his complaint, the parties engaged in discovery. A year and a half later, the defendants filed a motion requesting that the circuit court dismiss the matter with prejudice, due to May’s inconsistent and deliberately false testimony throughout the discovery process. The circuit court entered its decision after finding that May willfully concealed his past injuries and accidents, significantly prejudicing the defendants’ ability to proceed with their case. After reviewing the circuit court’s decision for an abuse of discretion, the Mississippi Supreme Court found the circuit court did not err in finding that the plaintiff committed numerous discovery violations which resulted in inordinate delay and increased costs to the defendants. As a result, the Court affirmed dismissal. View "May v. Austin" on Justia Law

A jury sentenced Willie Russell to death for murdering a correctional officer. Russell later claimed he was intellectually disabled and thus could not be executed under Atkins v.Virginia, 536 U.S. 304 (2002). In 2014, the trial court set an Atkins hearing to determine if Russell was intellectually disabled. Prior to the hearing, the State moved to assess Russell based on his claimed intellectual disability. But Russell opposed the State’s expert conducting the evaluation; years earlier, Russell had undergone psychological testing ordered in a separate aggravated-assault case. But that testing was for his competency to stand trial, not assessing intellectual disability. Although the State had initially proposed that the 2006 assessment cover both issues, Russell’s attorney also objected back then to the State evaluating Russell’s Atkins claim in that proceeding. So Russell was never evaluated on the specific criteria for intellectual disability under Atkins. The record showd both Russell and the State understood that the 2006 testing would not serve as his complete Atkins assessment. Even the State's expert felt additional testing was required. Still, the trial court denied the State’s motion to evaluate Russell, concluding the prior testing was sufficient. "Consequently, the court’s denial led to what was essentially a one-sided Atkins hearing." At the end of the hearing, the trial court ruled that Russell was intellectually disabled under Atkins and Chase v. Mississippi, 873 So.2d 1013 (Miss. 2004), and vacated his death sentence. The State appealed. After review, the Mississippi Supreme Court found the trial court reversibly erred: the trial judge abused her discretion by denying the State’s well-supported motion to evaluate Russell prior to the Atkins hearing. View "Mississippi v. Russell" on Justia Law

A same-sex couple conceived a child through the use of artificial insemination (AI) of sperm from an anonymous donor. Kimberly Day was the gestational mother; Z.S. was born in 2011 in Mississippi. The couple separated in 2013. In October 2016, the Rankin County Chancery Court entered a final judgment of divorce. In the judgment, the chancery court found, among other things, that Christina Strickland acted in loco parentis to Z.S., but that Christina was not Z.S.’s legal parent. Central to the chancery court’s decision was the finding that the anonymous sperm donor had parental rights that had to be terminated and thus precluded Christina from being Z.S.’s legal parent. Christina appealed, presenting a question of first impression to the Mississippi Supreme Court: whether the chancery court erred in finding that the rights of the anonymous sperm donor precluded a finding that Christina was Z.S.’s legal parent. After review of the record and the relevant law, the Supreme Court found the chancery court erred in this finding. First, an anonymous sperm donor is not a legal parent whose rights must be terminated. And second, the doctrine of equitable estoppel precluded Kimberly from challenging Christina’s legal parentage of Z.S. The chancery court’s judgment was reversed and the matter remanded for a custody determination. View "Strickland v. Day" on Justia Law

Jerry McGill saw someone in Bobby Brewer's Volvo and called police. McGill pursued the man on foot, later identified as Charles Naylor. Naylor had in his possession Brewer’s global positioning system (GPS) and an insurance card that bore Brewer’s name. He was convicted of burglary of an automobile and was sentenced, as an habitual offender pursuant to Mississippi Code Section 99-19-81 (Rev. 2015), to seven years’ imprisonment without parole. On appeal, Naylor claimed the evidence was insufficient to support his conviction. Finding no merit in Naylor’s claim on appeal, the Mississippi Supreme Court affirmed. View "Naylor v. Mississippi" on Justia Law

Tommy Brooks Oil Co. (“Brooks Oil”) challenged the trial court’s grant of summary judgment in favor of Jerry Wilburn. According to Brooks Oil, Wilburn Oil Co., Inc. (“Wilburn Oil”) had amassed nearly $1 million in unpaid fuel bills before Brooks Oil refused to sell Wilburn Oil any more fuel until Wilburn executed two personal guaranties for $250,000. After Brooks Oil sued Wilburn to enforce the guaranties, Wilburn moved for summary judgment, claiming a unilateral or mutual mistake concerning the guaranties. According to Wilburn, the parties never intended the guaranties to include Wilburn Oil’s past debt. The trial court agreed and granted summary judgment, dismissing Brooks Oil’s suit against Wilburn with prejudice. The Mississippi Supreme Court found Wilburn did not meet his summary-judgment burden, therefore, it reversed the trial court’s judgment and remanded the case for further proceedings. View "Tommy Brooks Oil Co. v. Wilburn Oil Company, Inc." on Justia Law

Pursuant to Mississippi Code Section 27-35-119 (Rev. 2017), Natchez Hospital Company, LLC, (“Hospital”) filed a Complaint and Petition For Reduction of Assessment on Software. This ad valorem assessment was made by the Adams County Board of Supervisors (“Board”). Prior to appealing to the circuit court, the Hospital paid the ad valorem taxes as assessed. The Board filed a motion to dismiss for lack of jurisdiction, arguing that the Hospital had failed to post the necessary appeal bond required by Mississippi Code Section 11-51-77 (Rev. 2012), thus depriving the circuit court of jurisdiction. Following a hearing on the motion, the circuit court determined that the Hospital’s failure to post the bond under Section 11-51-77 deprived the court of jurisdiction to hear the appeal and granted the Board’s motion to dismiss. The Hospital appealed the circuit court’s decision to dismiss the case, asking only whether the bond requirement of Mississippi Code Section 11-51-77 was mandatory to confer jurisdiction on a circuit court to hear an appeal from a decision of a board of supervisors regarding an assessment of taxes. The Mississippi Supreme Court determined the Hospital paid the tax, but that was no excuse for not posting the bond to give the trial court jurisdiction to hear its complaint. Therefore, the Supreme Court affirmed dismissal of the Hospital’s case. View "Natchez Hospital Company, LLC v. Adams County Board of Supervisors" on Justia Law

This interlocutory appeal arose from a 2010 civil suit filed by Carol Clement against Russell Puckett. After Puckett’s death in 2014, Clement substituted the Estate of Russell Puckett (the “Estate”) as the defendant in the suit and served the Estate. The Estate moved to dismiss the suit due to failure to timely serve process under Mississippi Rule of Civil Procedure 4(h). The Estate argued that the statute of limitations had expired before Clement perfected service. The trial court denied the motion to dismiss. The Estate appealed the trial court’s denial of the motion to dismiss. Because the trial court erred when it denied the motion to dismiss, the Mississippi Supreme Court reversed and rendered judgment in favor of the Estate. View "Estate of Russell Puckett v. Clement" on Justia Law