Madison Taylor

Mississippi Court of Appeals Decisions of August 8, 2023

The Mississippi Court of Appeals handed down ten opinions today. There are a bunch of domestic relations cases, several direct criminal appeals (with some jury instruction issues), a workers’ comp decision addressing the compensability of a COVID diagnosis, and a real property case. I learned about the “fugitive dismissal rule” today and you can too.

Covin v. Covin, 2022-CA-00019-COA (Civil – Domestic Relations)
Affirming the chancellor’s decision finding both parties to a divorce in contempt and denying both parties’ request for attorney’s fees, holding that the chancellor did not err in making a sua sponte clarification of final judgment of divorce, in finding one side in contempt for failing to refinance the marital home and remit the other side’s equitable interest within the court-ordered timeline and for not allowing the other side to retrieve personal property, or in not awarding attorney’s fees despite contempt findings.
(9-1-0: Lawrence concurred in part and in the result sub silentio.)

Carpenter v. State, 2022-KA-00398-COA (Criminal – Felony)
Affirming conviction or attempted murder and possession of a firearm by a felon, holding that it was not plain error to not instruct the jury on the elements of murder and that the instruction give adequately described the crime of attempted murder.
(7-3-0: Wilson and McDonald concurred in part and in the result sub silentio; Westbrooks concurred in the result only sub silentio.)

NOTE – Here are the instructions at issue. S-1 read:

And S-2 read:

White v. State, 2021-KA-00818-COA (Criminal – Felony)
Affirming convictions of jointly-tried defendants for drive-by shooting and shooting into a swelling, holding that the convictions were supported by sufficient evidence and that the verdicts were not against the overwhelming weight of the evidence.
(10-0)

Davis v. State, 2022-KA-00573-COA (Criminal – Felony)
Affirming conviction for armed robbery with sentence enhancement based on the victim’s age, holding that the trial court did not abuse its discretion in denying a motion for new trial based on weight of the evidence arguments or in refusing to give a lesser-included-offense instruction for simple assault.
(10-0)

Gardner v. State, 2021-KA-00886-COA (Criminal – Felony)
Affirming convictions of first-degree murder and attempted murder, holding that the trial court did not err by not striking a jail minister for cause or by finding a child competent to testify, that the issue of limitations put on on cross-examination were waived for failure to object, and that there was no plain error in accepting the State’s jury instruction that did not contain the word “deliberate.”
(6-4-0: Wilson and Emfinger concurred in part and in the result sub silentio; Greenlee and Lawrence concurred in result only sub silentio.)

NOTE – Here is the jury instruction at issue:

Davidson v. Davidson, 2022-CA-00372-COA (Civil – Domestic Relations)
Affirming in part and reversing in part the chancellor’s decision related to property and debt division in a divorce proceeding, holding that the chancellor did not err in classification of marital assets or award of equity in the marital home but the order dividing the debt incurred on a credit card was not sufficiently clear regarding the amount to divide and remanding for a proper finding as to the amount.
(9-1-0: Greenlee concurred in result only sub silentio.)

Jones v. State, 2021-KA-01375-COA (Criminal – Felony)
Affirming conviction of second-degree murder, holding that the verdict was not contrary to the overwhelming weight of the evidence and that the trial court did not err in refusing a jury instruction on the excuse of accident where the defendant never stated he accidentally fired the gun.
(9-1-0: Westbrooks concurred in part and in the result sub silentio.)

West v. The Nichols Center, 2021-WC-01403-COA (Civil – Workers’ Comp)
Affirming the Commission’s finding that a nurse’s COVID diagnosis and resulting blood clot after treating COVID-positive patients was not compensable, holding that there was no lay or medical proof that the claimant contracted COVID at work.
(10-0)

PRACTICE POINT – For those of us who handle workers’ comp claims, this was an interesting footnote regarding the necessity of medical proof. I was anticipating a discussion of whether COVID falls under the statutory definition of an “accidental injury” or an “occupational disease” but this footnote explains why we didn’t get it.

Gillen v. Gillen, 2021-CA-00837-COA (Civil – Domestic Relations)
Dismissing appeal of a contempt order in a divorce proceeding, holding that the party in contempt under the “fugitive dismissal rule” because he had absented himself from the chancery court’s jurisdiction to avoid incarceration for contempt.
(10-0)

PRACTICE POINT – Be sure to add the “fugitive dismissal rule” to your arsenal:

Tubwell v. FV-1, 2021-CP-01345-COA (Civil – Real Property)
Affirming the circuit court’s decision dispossessing the defendant of land he refused to vacate after the property was foreclosed on, holding that the circuit court had jurisdiction, that the circuit court did not err in denying the defendant’s motion to dismiss based on the statute of limitations and adverse possession, that the plaintiff was entitled to summary judgment on the issue of the defendant’s failure to vacate the property, and that the circuit court did not err in dismissing the counterclaim without prejudice.
(3-2-5: McCarty concurred in part/in result sub silentio; Carlton concurred in result only sub silentio; Barnes, Westbrooks, McDonald, and Emfinger concurred in part/dissented in part sub silentio; Wilson concurred in part and dissented in part, joined by Barnes, and Emfinger, and joined in part by Westbrooks, McDonald, and McCarty.)

Other Orders

Lofton v. Lofton, 2021-CT-00035-COA (granting motion for supplemental attorney’s fees)

Brown v. Brown, 2021-CA-00728-COA (dismissing pro se motions for lack of jurisdiction)

Nunn v. State, 2021-KA-01371-COA (denying rehearing)

Brown v. State, 2022-CP-00069-COA (recalling mandate and granting additional rehearing time)

Hamilton v. State, 2022-CP-00069-COA (granting pro se motion for extension of time to file motion for rehearing)

Parker v. MDH, 2022-WC-00552-COA (denying rehearing)

Wells v. State, 2022-KA-00707-COA (granting motion to recall mandate and reinstate appeal)

Fox v. State, 2022-KA-00988-COA (granting motion for leave to file amicus brief)

Pryer v. State, 2023-TS-00568-COA (denying motion for reconsideration)

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Mississippi Supreme Court Decisions of August 3, 2023

The Mississippi Supreme Court handed down one opinion today but it is not an insignificant day. The opinion is in an MTCA reckless disregard case stemming from a police officer who crashed into a bystander vehicle while crossing an intersection en route to another accident scene. The trial court found for the City after a bench trial, the Court of Appeals reversed, and the Supreme Court granted cert.

Phillips v. City of Oxford, 2021-CT-00639-SCT (Civil – Personal Injury/MTCA)
Reversing the COA and reinstating/affirming the circuit court’s judgment for the City, holding that the record contained sufficient evidence to support the trial court’s decision that the officer did not act in reckless disregard while responding to a rollover wreck when he struck a bystander vehicle while crossing an intersection and exceeding the speed limit but also where he had his lights and sirens on and, when approaching intersections, he slowed his speed and used his horn as an additional warning.
(6-2: Kitchens dissented, joined by King. Maxwell did not participate.)

NOTE – This opinion emphasized the “deferential standard of review” for a bench trial under the MTCA and the fact that “reckless disregard” is an “extremely high bar” that is a higher standard than gross negligence.

Other Orders

In Re: Commission on Mandatory Continuing Legal Education, 89-R-99011-SCT (Reappointing George Scott Luter, Richard W. Sliman, and John Dickson Mayo to three-year terms (Aug. 1, 2023, through July 31, 2026) as members of the Commission on Mandatory Continuing Legal Education)

Colburn v. State, 2021-CT-00865 (denying cert)

In Re: Administrative Orders of the Supreme Court of Mississippi, 2023-AD-000001-SCT (Directing the disbursement of $179,389.36 in civil legal assistance funds among the MS Center for Legal Services, MS Volunteer Lawyers Project, and North MS Rural Legal Services)

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Mississippi Court of Appeals Decisions of August 1, 2023

The Mississippi Court of Appeals handed down six opinions today. We have a couple of state boards and agencies decisions, one dealing with recall of a police officer’s certification and the other with a termination of a teacher and suspension of license. There is a real property case involving a church and the invocation of the “ecclesiastical abstention doctrine,” a direct criminal appeal, and two PCR cases.

As a housekeeping note, I have started writing “sub silentio” instead of “without separate written opinion” to indicate concurrences and dissents without separate written opinions. I am not aware of that phrase being used in that specific manner, but I think it gets the point across. This may not seem like a big deal, and it really isn’t, but the frequency with which I have been typing “without separate written opinion” has become a thief of joy for this humble blogger of case summaries.

Walters v. Board on Law Enforcement Officer Standards and Training, 2022-SA-00378-COA (Civil – State Boards and Agencies)
Affirming the chancery court’s decision affirming Board’s decision to recall a police officer’s processional certification, holding that the Board’s decision was not arbitrary and capricious, did not violate the former officer’s constitutional rights, and were supported by substantial evidence including evidence of unnecessary force, violations of department policies, and racist text messages.
(10-0)

NOTE– The Court also granted in part a motion from the Board to unseal the case file.

Pickle v. State, 2022-CP-00929-COA (Civil – PCR)
Affirming the circuit court’s decision denying a motion to vacate a sentence for capital murder while committing criminal rape from 1978, holding that the petitioner was not illegally sentenced and that he was not entitled to a Miller resentencing hearing.
(8-2-0: Emfinger concurred in part and in the result sub silentio; Lawrence concurred in the result only sub silentio.)

Greater New Hamilton Grove Baptist Church v. Hamilton Grove Missionary Baptist Church, 2022-CA-00518-COA (Civil – Real Property)
Affirming the chancellor’s ruling that a deed purporting to convey real property owned by a church was invalid because it was not authorized by a resolution under section 79-11-31(1), holding that the chancellor was not deprived of subject matter jurisdiction under the “ecclesiastical abstention doctrine,” that the “minutes rule” was not applicable because a church is not a public board, and the chancellor did not abuse her discretion in granting the plaintiff leave to file an amended complaint.
(10-0)

NOTE – I thought the Court’s summary of its decision on the ecclesiastical abstention doctrine was interesting:

Badger v. State, 2022-CP-00831-COA (Civil – PCR)
Affirming denial of the petitioner’s third motion for PCR twelve years after pleading guilty, holding that the circuit court did not err in finding that the motion was time-barred and did not meet any statutory exception under the UPCCRA or any fundamental rights exception that was in effect at that time.
(8-2-0: Westbrooks concurred in result only sub silentio.)

Langley v. Miss. State Board of Education, 2022-SA-01024-COA (Civil – State Board and Agencies)
Affirming the BOE’s decision upholding a teacher’s termination for violations of the BOE’s standards of conduct, suspending her license for five years, and placing conditions on reinstatement, holding that the Commission’s decision as upheld by the Board and the chancery court was supported by substantial evidence and was not arbitrary or capricious, the Commission was authorized to suspect her license, and she was afforded due process at her hearing.
(10-0)

West v. State, 2022-KA-00432-COA (Criminal – Felony)
Affirming conviction of sexual battery and gratification of lust, both while in position of trust and authority, holding that the defendant’s sufficiency of the evidence argument was procedurally barred because it was not raised before the circuit court and that the circuit court did not commit plain error in not sua sponte declaring a mistrial.
(5-3-2: Barnes, McDonald, and Emfinger concurred in part and in the result sub silentio; Greenlee concurred in part and dissented in part sub silentio; Westbrooks concurred in part and dissented in part, joined by McDonald and Greenlee in part)

Other Orders

Wakefield v. State, 2021-KA-00187-COA (denying rehearing)

Estate of Bell v. Estate of Bell, 2021-CA-00789-COA (denying rehearing)

Anderson v. State, 2021-KA-01340-COA (denying rehearing)

McDowell v. State, 2021-CA-01381-COA (denying rehearing)

Everett v. State, 2021-CP-01415-COA (denying rehearing)

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Mississippi Supreme Court Decisions of July 27, 2023

The Mississippi Supreme Court handed down two opinions in direct criminal appeals today. One involved the adequacy of the indictment and sentencing as a habitual offender. The other raised issues of weight and sufficiency of evidence, the trial court’s failure to rule on an objection during trial, closing argument, and the racial composition of the jury. One ended in a reversal and the other an affirmance.

Young v. State, 2021-KA-00940-SCT (Criminal – Felony)
Reversing sentence as a habitual offender, holding that the indictment failed to comply with Rule 14.1(b)(1) but defendant waived the issue of defective indictment by failing to object to it in the trial court but also holding that the evidence was insufficient to support the habitual offender sentence and remanding for resentencing.
(9-0)

Redd v. State, 2022-KA-00175-SCT (Criminal – Felony)
Affirming conviction of aggravated assault causing bodily injury, holding that the verdict was supported by sufficient evidence and not against the overwhelming weight of it, that the defendant waived his objection to testimony by failing to request corrective action from the trial court, that the State was entitled to draw inferences from facts in the record during closing, and that the issue of the racial composition of the jury was procedurally barred and without merit because the defendant did not object to the racial composition and the record was silent about the composition.
(9-0)

Other Orders

In Re: Mississippi Rules of Appellate Procedure, 89-R-99027-SCT (amending Miss. R. App. P.)

Parker v. Ross, 2020-CT-01055-SCT (denying motion for costs)

Yarborough v. Singing River Health Systems, 2021-CT-00668-SCT (denying cert)

The Banking Group, Inc. v. Southern Bancorp Bank, 2021-CT-01077-SCT (denying cert)

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Mississippi Court of Appeals Decisions of July 25, 2023

The Mississippi Court of Appeals handed down five opinions today covering diverse subject matter. There is a zoning exception case, a custody case, a personal injury case considering a grant of summary judgment in a slip-and-fall case, a marital property division case analyzing whether a PSA was ambiguous, and a PCR case with a concurrence discussing Howell/Rowland I/Rowland II.

Keenum v. City of Moss Point, 2021-CA-01044-COA (Civil – Other/Zoning)
Reversing the circuit court’s decision that affirmed the mayor’s decision to approve a special exception to a zoning ordinance, holding that the decision to allow a for-profit development in a residential-zoned area under an exception for “semi-public recreational area” (which was not defined in the ordinance) was reversible error because that reading would render the prohibition against “commercial use” in the ordinance meaningless.
(8-1-0: McDonald concurred in part and in the result without separate written opinion; Lawrence did not participate.)

D.W.K. v. Youth Court of Lincoln County, 2019-CP-00451-COA; 2020-CP-01307-COA (Civil – Custody)
Affirming the youth court’s denial of motions to consider new evidence two years after adjudication of abuse and neglect and placement of five minor children with their maternal aunt, holding that the youth court had jurisdiction; service of process was proper; that the youth court’s decision was not manifestly wrong or erroneous, was based on substantial evidence, and favored the best interest of the children; and that the record on appeal was sufficient.
(10-0)

Babin v. Wendelta, Inc., 2022-CA-00341-COA (Civil – Personal Injury)
Reversing the circuit court’s grant of summary judgment for a fast food restaurant in a slip-and-fall case, holding that “the record contained ample proof” of a dangerous condition where multiple witnesses including restaurant employees testified that the mat was slippery on the date of the fall and that the vestibule where the mat was located held condensation.
(9-1-0: Lawrence concurred in result only WOSWO.)

Practice Point – I have noticed ANSI standards appearing more frequently in my practice. I suspect these two sentences will make their way into more than one brief:

Blanchard v. Blanchard, 2022-CA-00356-COA (Civil – Domestic Relations)
Reversing the chancery court’s ruling based on parol evidence after finding that a Property Settlement Agreement was ambiguous, holding that the PSA was unambiguous and that it entitled the ex-husband to half of the net proceeds of the sale of the former marital home even though the ex-wife had refinanced the home.
(10-0)

Roberson v. State, 2021-CA-01182-COA (Civil – PCR)
Affirming order granting in part and denying in part a PCR motion, holding that the petitioner was not entitled to an exception from the statutory bars and that, in any event, there was no merit to his claim that his plea was involuntary or that his counsel was ineffective.
(6-4-0: Westbrooks, McDonald, and McCarty concurred in part and in the result WOSWO; Wilson concurred in part and in the result, joined by McDonald and McCarty and joined in part by Westbrooks.)

Note – Judge Wilson’s concurrence discussed the state of the “fundamental-rights exception” in light of the Mississippi Supreme Court in Howell overruling Rowland I and Rowland II, and noted that the Supreme Court had not squarely addressed whether the successive motions bar is substantive or procedural:

Other Orders

Buchanan v. State, 2021-CP-01069-COA (denying rehearing)

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Mississippi Supreme Court Decisions of June 29, 2023 (catch-up post)

The Mississippi Supreme Court handed down two opinions on June 29. The first was an estate case addressing claims of undue influence. The other was a personal injury case on interlocutory appeal of the denial of an insurer’s motion for summary judgment on the issue of whether an employer’s CGL policy provided coverage for an employee’s motor vehicle accident using company equipment.

Estate of Biddle v. Biddle, 2021-CP-00513-SCT (Civil – Wills, Trusts & Estates)
Affirming the chancellor’s decisions in an estate matter, holding that venue and jurisdiction were waived by the testator’s sons because those issues were raised for the first time in response to their stepmother’s motion for summary judgment and that the evidence did not create a genuine issue of material fact concerning the existence of “suspicious circumstances” rising to the level of undue influence of the wife over her husband.
(9-0)

Penn-Star Ins. Co. v. Thompson, 2022-IA-00106-SCT (Civil- Personal Injury)
Reversing the trial court’s denial of an insurer’s motion for summary judgment in a motor vehicle negligence action, holding that there was no coverage under the company’s CGL policy where an employee of a welding company was involved in a collision while operating a forklift owned by the company to tow his personal truck to the company’s premises to self-perform repairs because the collision did not “arise out of or relate to” the welding operations.
(9-0)

Other Orders

Watts v. Watts, 2021-CT-00321-SCT (denying cert)

$41,000 v. State, 2021-CT-00692-SCT (denying cert)

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Mississippi Supreme Court Decisions of July 6, 2023 (catch-up post)

On Thursday, July 6, the Mississippi Supreme Court handed down three opinions. Two are direct criminal appeals and one is an civil appeal addressing the statutes of limitations for MTCA claims and state constitutional claims.

Stewart v. State, 2022-KA-00479-SCT (Criminal – Felony)
Affirming conviction of possession of meth, holding that the defendant waived his Fourth Amendment and Miranda rights arguments by not raising them at trial court, and then waived plain error arguments on appeal by not raising them until the reply brief after the State asserted waiver, and further that the “sparse record” did not show plain error.
(9-0)

Moton v. Clarksdale, 2022-CA-00216-SCT (Civil – Torts)
Denying rehearing but withdrawing the original opinions and substituting another holding that the trial court correctly found that a city commissioner’s tort law claims stemming from his arrest were barred by the MTCA’s statute of limitations and that the claims arising under the Mississippi Constitution were barred by the general statute of limitations.
(9-0)

Mitchell v. State, 2021-KA-00589-SCT (Criminal – Felony)
Affirming conviction of second-degree murder, holding that there was insufficient evidence in the record to find that a due process violation occurred when the trial court denied the defendant’s request for the production of an autopsy report and then denied a request to conduct an autopsy.
(9-0)

Other Orders

Barber v. State, 2022-KA-00291-SCT (per curiam affimance)

Lofton v. Lofton, 2021-CT-00035-SCT (denying cert)

Clark v. Vicksburg Healthcare, LLC, 2021-CT-00173-SCT (denying motion to strike cert petition, granting motion to suspend the rules, accepting the filing of a cert petition, and denying cert)

Griffin v. State, 2023-M-00262 (denying mandamus)

Carr v. State, 2023-DR-00503-SCT (remanding PCR issues to circuit court)

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Mississippi Court of Appeals Decisions of July 18, 2023

I am declaring an end to the hiatus caused by the tree falling on my house. That war rages on, but these decisions are not going to summarize themselves. I aspire to go back and summarize the decisions handed down while I was down, but I am going to prioritize summarizing new hand downs going forward.

On Tuesday, the Court of Appeals handed down four opinions. One is an appeal of a verdict in a med mal bench trial. The other three are PCR cases, one of which yielded a 5-1-4 split.

Singing River Health System v. Brand, 2022-CA-00090-COA (Civil – Med Mal)
Affirming judgment for the plaintiff in a med mal case against a hospital after a bench trial, holding that the hospital’s vicarious liability argument was procedurally barred because it not raised at the trial court level, that the plaintiff’s experts were qualified to testify about a breach of the standard of care and cause of death and provided sufficient evidence under the “lost chance of recovery” theory, and that there was substantial evidence to support the trial court’s findings.
(8-1-0: Wilson concurred in result only; Lawrence did not participate.)

Tate v. State, 2021-CP-01237-COA (Civil – PCR)
Affirming denial of PCR motion, holding that the trial court did not err determining that there was no evidence showing that the plea of guilt was involuntary or that counsel was ineffective.
(9-0: Emfinger did not participate.)

Havercome v. State, 2022-CA-00391-COA (Civil – PCR)
Affirming dismissal of PCR motion, holding that the motion was barred by the UPCCRA.
(10-0)

Love v. State, 2021-CP-01101-COA (Civil – PCR)
Affirming dismissal of motion for PCR, holding that the trial court did not err in finding that there was a factual basis for his plea, that the please was voluntary, that the claim to withdraw his plea was time-barred, and that counsel was not ineffective.
(5-1-4: McDonald concurred in part and in the result without written opinion; Emfinger dissented, joined by Wilson, Westbrooks, and McCarty, and joined in part by McDonald.)

Other Orders

Alford v. State, 2022-KA-00025-COA (denying rehearing)

Hopes v. State, 2022-KA-COA (denying rehearing)

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Expect Delays

Due to some “technical difficulties” here at the Mississippi Appeals blog, there will be a brief pause on case summaries.

We were not at home when the tree fell on our house so we are all good from that standpoint. We are immensely thankful for family, friends, and neighbors who jumped right in and helped us out! Our church family at Pear Orchard Presbyterian Church has supported immeasurably. They showed up en masse to help on the night the tree fell and have been pouring out all manner of assistance ever since including housing, food, and compassion. We are so thankful for God’s provision through his people (Romans 12:13).

Mississippi Court of Appeals Decisions of June 13, 2023

I was out of town for a wedding anniversary trip on Tuesday, and then I have been playing catch-up at the office to recover from said trip, so my summaries are delayed this week. First up is Tuesday’s offering from Mississippi Court of Appeals. The COA handed down five opinions this week: a termination of parental rights case, an emancipation case, two direct criminal appeals, and an attempted appeal of a MDOC decision.

Rogers v. Kresse, 2021-CA-00914-COA (Civil – Custody)
Affirming termination of parental rights, holding that the chancery court did not err in finding that the natural mother had abandoned her children and that the father had not abused his discretion with regard to visitation by disallowing it, and that reunification was not in the children’s best interest.
(7-2-0: McDonald concurred in part in and the result without separate written opinion; Westbrooks concurred in result only without separate written opinion.)

Talley v. Talley, 2022-CA-00005-COA (Civil – Domestic Relations)
Affirming the chancellor’s judgment in an emancipation proceeding initiated by a father with a counter-petition for contempt for failure to pay filed by the mother, holding that the chancellor did not err by finding that the children were emancipated while not modifying the life insurance provision of the divorce agreement, finding the father in contempt for failing to pay his portion of certain expenses, and awarding the mother attorney’s fees.
(9-0: Barnes did not participate.)

Allen v. State, 2022-KA-00331-COA (Criminal – Felony)
Affirming conviction of selling fentanyl and trafficking and possession of controlled substances while possessing a firearm, holding that the circuit court did not err in admitting text messages into evidence on authentication, relevance, or hearsay grounds.
(7-3-0: Wilson concurred in part and in the result without separate written opinion; Westbrooks and McDonald concurred in result only without separate written opinion.)

Wallace v. State, 2022-KA-00332-COA (Criminal – Felony)
Affirming conviction of first-degree murder, holding that the trial court did not err in denying the defendant’s request for a heat-of-passion manslaughter instruction or by allowing testimony related to injuries the victim suffered a week before her death.
(9-0: Smith did not participate.)

NOTE– I love it when opinions cut to the chase. Introductions like this would just about put me out of business around here:

Knight v. State, 2021-CP-01192-COA (Civil – State Boards & Agencies)
Dismissing an appeal for lack of jurisdiction, holding that the appeal of a purported PCR motion was untimely and because it was actually a petition seeking judicial review of an MDOC decision it was a civil appeal for which the Court could not suspend the rules to allow an untimely appeal.
(10-0)

Other Orders

McKenzie v. State, 2012-KA-00471-COA (dismissing untimely motion for rehearing)

Thomas v. State, 2021-CP-00060-COA (denying rehearing)

Pace v. State, 2022-KA-00046-COA (denying rehearing)

Jones v. State, 2023-TS-00325-COA (dismissing appeal as untimely)

Bates v. State, 2023-TS-00356-COA (allowing appeal to proceed as timely based on well-taken pro se show-cause response)

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