Cameron Deandre Bracey v. Montgomery County, Mississippi

Court of Appeals of Mississippi·Decided August 25, 2026·No. 2025-CA-00369-COA·Published

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI NO. 2025-CA-00369-COA

CAMERON DEANDRE BRACEY APPELLANT v. MONTGOMERY COUNTY, MISSISSIPPI APPELLEE

DATE OF JUDGMENT: 03/18/2025 TRIAL JUDGE: HON. JOSEPH H. LOPER JR. COURT FROM WHICH APPEALED: MONTGOMERY COUNTY CIRCUIT COURT

ATTORNEYS FOR APPELLANT: FRANK G. VOLLOR TRACIE DIANE HERRING

ATTORNEYS FOR APPELLEE: ROBERT J. DAMBRINO III WESLEY CLAYTON PINSON

NATURE OF THE CASE: CIVIL - TORTS-OTHER THAN PERSONAL INJURY & PROPERTY DAMAGE

DISPOSITION: AFFIRMED IN PART; REVERSED AND REMANDED IN PART - 08/25/2026 MOTION FOR REHEARING FILED:

BEFORE WILSON, P.J., EMFINGER AND LASSITTER ST. PÉ, JJ.

WILSON, P.J., FOR THE COURT:

¶1. Cameron Bracey alleged that the Montgomery County Sheriff’s Department caused him to be charged with forgery and arrested based solely on a cursory internet search for the name of the payee on a forged check. Bracey sued Montgomery County for malicious prosecution and false arrest/imprisonment under the Mississippi Tort Claims Act (MTCA), Miss. Code Ann. § 11-46-1 to -23 (Rev. 2019). The circuit court granted the County’s motion for judgment on the pleadings, holding that Bracey’s malicious prosecution claim was barred by sovereign immunity under the MTCA and that Bracey’s false arrest/imprisonment

claim was barred by the statute of limitations.

¶2. We affirm the dismissal of Bracey’s malicious prosecution claim. However, we conclude that Bracey may pursue his false arrest/imprisonment claim under the MTCA, that the claim is not barred by the applicable statute of limitations, and that Bracey has alleged sufficient facts to survive a motion for judgment on the pleadings on that claim. Accordingly, we affirm in part, reverse in part, and remand for further proceedings on Bracey’s false arrest/imprisonment claim.

FACTS AND PROCEDURAL HISTORY1

¶3. Edwin Taylor & Son Logging (“Taylor & Son”) is a business located in Duck Hill, Mississippi. In April or May 2023, Taylor & Son was notified that a duplicate check for $5,047.31 had been drawn on its account with the Bank of Kilmichael and deposited in an account at First Tennessee Bank in Memphis. The check was payable to “Cameron Bracey.” Taylor & Son reported the forged check to the Montgomery County Sheriff’s Department.

¶4. In response to Taylor & Son’s report, the sheriff’s department allegedly conducted a “cursory investigation” consisting of only a “cursory social media scan and internet search” for an individual with a similar name. The sheriff’s department identified Cameron Bracey, a twenty-two-year-old Jackson State University student and Vicksburg resident. The sheriff’s department then had Edwin Taylor, the sole proprietor of Taylor & Son, sign a criminal affidavit accusing Bracey of forgery.

1 Because we review an order granting a motion for judgment on the pleadings, the complaint’s factual allegations must be taken as true. Broadband Voice LLC v. Jefferson County, 348 So. 3d 305, 307 (¶10) (Miss. 2022).

¶5. Bracey had never been associated with or employed by Taylor & Son, he had no access to its checks, and he had no connection to the Memphis bank account in which the forged check was deposited. Nonetheless, the Montgomery County Justice Court issued a warrant for Bracey’s arrest. On July 2, 2023, he was arrested and detained in Vicksburg and transported to Montgomery County. On July 4, 2023, for reasons that are unclear, a justice court judge set bail at $100,000. Bracey paid $10,075 to a bail bondsman to secure his release and a $4,000 retainer to a criminal defense attorney. Bracey also lost his job as a result of his arrest. Bracey’s preliminary hearing was continued at the State’s request, and in September 2023 the justice court bound the case over to the grand jury. The prosecution ended in March 2024 when a Montgomery County grand jury returned a “No Bill.”

¶6. In June 2024, Bracey served Montgomery County with a notice of claim pursuant to the MTCA. See Miss. Code Ann. § 11-46-11 (Rev. 2019). In October 2024, Bracey sued the County under the MTCA in the Montgomery County Circuit Court. The complaint asserted claims for malicious prosecution and false arrest/false imprisonment.2

¶7. The County filed a motion for judgment on the pleadings, arguing that both claims were barred by sovereign immunity under the MTCA and that because the claims were not covered by the MTCA, they were also barred by the one-year statute of limitations found in Mississippi Code Annotated section 15-1-35 (Rev. 2019).

¶8. The circuit court granted the County’s motion, holding that sovereign immunity barred

2 Bracey filed a separate complaint in the Montgomery County Circuit Court that asserted the same two claims against Taylor & Son. Bracey filed a motion to consolidate the two cases, but the circuit court did not rule on that motion.

Bracey’s malicious prosecution claim and that the statute of limitations barred his false arrest/false imprisonment claim. Bracey filed a notice of appeal.

ANALYSIS

¶9. We review an order granting a motion for judgment on the pleadings de novo. R.J. Reynolds Tobacco Co. v. King, 921 So. 2d 268, 270 (¶10) (Miss. 2005). “A Rule 12(c) motion is similar to a Rule 12(b)(6) motion to dismiss for failure to state a claim upon which relief can be granted.” Id. at 271 (¶10). Therefore, “the allegations in the complaint must be taken as true, and the motion should not be granted unless it appears beyond any reasonable doubt that the non-moving party will be unable to prove any set of facts in support of the claim which would entitle the non-movant to relief.” Id.

I. Malicious Prosecution

¶10. The County argues that Bracey’s claim for malicious prosecution is barred by sovereign immunity under the MTCA. We agree.

¶11. “The MTCA statutorily replaced the common-law doctrine of sovereign immunity.” Univ. of Miss. Med. Ctr. v. Oliver, 235 So. 3d 75, 81 (¶24) (Miss. 2017). The MTCA waives “the immunity of the state and its political subdivisions from claims for money damages arising out of the torts of such governmental entities and the torts of their employees while acting within the course and scope of their employment.” Miss. Code Ann. § 11-46-5(1) (Rev. 2019). However, the MTCA also provides that a governmental entity does not “waive[] immunity for any conduct of its employee if the employee’s conduct constituted fraud, malice, libel, slander, defamation or any criminal offense other than traffic violations.”

Miss. Code Ann. § 11-46-5(2) (emphasis added).

¶12. In Oliver, the plaintiff sued the University of Mississippi Medical Center (UMMC) for malicious prosecution after UMMC law enforcement officers filed criminal charges against him. See Oliver, 235 So. 3d at 77-79 (¶¶4-12). However, the Mississippi Supreme Court held that the plaintiff’s claim was barred by sovereign immunity:

[B]ased on the clear language of Section 11-46-5(2), . . . the MTCA does not apply to a malicious-prosecution claim against a governmental entity and its employees in their official capacity.

Under Section 11-46-5(2), torts in which malice is an essential element are not within the course and scope of employment. Thus, these intentional torts are outside the scope of the MTCA’s waiver of immunity, and the MTCA does not apply. Rather, any legal action against a governmental employee for these intentional torts must necessarily proceed against him or her as an individual.

Malice is an essential element of malicious prosecution. This means, to prove UMMC’s officers committed malicious prosecution, Oliver must prove the officers acted with malice. If he meets this burden, then necessarily he has proven they were acting outside the course and scope of their employment for purposes of the MTCA.

For UMMC, this means, as a matter of law, it cannot be liable, and sovereign immunity cannot be considered to have been waived for the alleged malicious conduct of its officers.

Id. at 82-83 (¶¶29-32) (citations and quotation marks omitted).

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