Mississippi Supreme Court Decisions of July 28, 2022

The Mississippi Supreme Court handed down two opinions today. One untangles a web of statutes governing sixteenth section land to determine whether a noncustodial school district could recover past revenue from the custodial school district. The other considered whether a conviction in a second trial violated double jeopardy after the first trial ended in a mistrial.


Wayne County School District v. Quitman School District, 2020-CA-00499-SCT (Civil – Other)
Reversing and rendering on direct appeal and affirming on cross-appeal in a dispute between to school districts about whether revenue generated from sixteenth section land received by the custodial district should have been shared with the noncustodial district, holding that the noncustodial district could not recover past revenue that might have been owed because the noncustodial district did not satisfy Section 29-3-119(4) which places a time limit on when a noncustodial district can make a claim with a custodial district.
(6-3: Justice Griffis dissented, joined by Justice Kitchens and Justice King.)

NOTE – This opinion takes a deep dive to interpret the statutes governing revenue generated by sixteenth section land. At stake was $1,101,413 in funds that the Wayne County School District collected and kept, but that the Quitman School District but could have had a claim to. Here is the Supreme Court’s conclusion:


Wilson v. State, 2021-KA-00473-SCT (Criminal – Felony)
Affirming conviction of aggravated assault, holding that double jeopardy was not violated because the trial court did not abuse its discretion when it found manifest necessity for a mistrial when the defendant’s first trial ended in a mistrial after the defense referenced the victim was incarcerated during opening and holding that the the weight of the evidence was such that allowing the verdict to stand was not an unconscionable injustice.
(7-2: Justice King dissented, joined by Justice Kitchens.)


Other Orders

Jackson v. State, 2014-M-00623 (denying petition for PCR and restricting the plaintiff from filing further PCR applications in forma pauperis)

Ladner v. State, 2020-CT-00299-SCT (denying cert)

Dew v. Harris, 2020-CT-01261-SCT (denying cert)

Kirk v. State, 2022-M-00044 (denying petition for PCR and restricting the plaintiff from filing further PCR applications in forma pauperis)


Hand Down List

Author: Madison Taylor

Shareholder at Wilkins Patterson in Mississippi handling appeals as well as all stages of liability and workers' compensation matters. Admitted to the bar in Mississippi, Tennessee, and North Carolina.

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