Carl Bailey, as a Constable of Western District of Jefferson County v. Jefferson County Board of Supervisors

CourtCourt of Appeals of Mississippi
DecidedJune 1, 2021
Docket2019-CC-01404-COA
StatusPublished

This text of Carl Bailey, as a Constable of Western District of Jefferson County v. Jefferson County Board of Supervisors (Carl Bailey, as a Constable of Western District of Jefferson County v. Jefferson County Board of Supervisors) is published on Counsel Stack Legal Research, covering Court of Appeals of Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Carl Bailey, as a Constable of Western District of Jefferson County v. Jefferson County Board of Supervisors, (Mich. Ct. App. 2021).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2019-CC-01404-COA

CARL BAILEY, AS A CONSTABLE OF APPELLANT WESTERN DISTRICT OF JEFFERSON COUNTY

v.

JEFFERSON COUNTY BOARD OF APPELLEE SUPERVISORS

DATE OF JUDGMENT: 08/02/2019 TRIAL JUDGE: HON. FRANK G. VOLLOR COURT FROM WHICH APPEALED: JEFFERSON COUNTY CIRCUIT COURT ATTORNEY FOR APPELLANT: WALTER HOWARD ZINN JR. ATTORNEY FOR APPELLEE: NICKITA SHANTA BANKS NATURE OF THE CASE: CIVIL - OTHER DISPOSITION: REVERSED AND REMANDED - 06/01/2021 MOTION FOR REHEARING FILED: MANDATE ISSUED:

EN BANC.

GREENLEE, J., FOR THE COURT:

¶1. After the Jefferson County Board of Supervisors removed Carl Bailey from office,

Bailey filed a bill of exceptions in the Jefferson County Circuit Court. He subsequently filed

a combined petition for a temporary restraining order and a motion for a preliminary

injunction. Ultimately, the court found that Bailey’s bill of exceptions was untimely filed,

and the court held, “It is therefore ordered and adjudged that the relief sought in the Petition

For Temporary Restraining Order and Motion for Preliminary Injunction is denied and the

present action is dismissed for lack of jurisdiction.” After review, we find that the court

erred by dismissing Bailey’s bill of exceptions for lack of jurisdiction, and we remand for further proceedings.

FACTS AND PROCEDURAL HISTORY

¶2. According to the Board, Bailey assumed office as the constable for the western district

of Jefferson County in January 2016. However, the Board alleged that in April 2016, Bailey

moved out of his district. In a letter dated November 23, 2016, the county administrator

informed Bailey that his move had violated election laws and requested his appearance at the

next scheduled board meeting on December 5, 2016.

¶3. In September 2017, the Board filed a complaint for writ of quo warranto in the circuit

court. The Board asserted that Bailey continued to act as constable, preventing the Board

from filling the position or calling a special election. The Board attached a letter dated

January 18, 2017, requesting the district attorney to initiate a quo warranto proceeding. But

according to the Board, the district attorney had not issued a letter of declination or initiated

such a proceeding.

¶4. On March 8, 2018, the circuit court filed an order of dismissal without prejudice. The

court held that the Board’s public writ could not proceed because it had not been brought by

a proper party for the State—the district attorney or Attorney General. In addition, the court

held that the Board’s private writ could not proceed because “[t]he statute providing for quo

warranto relief requires a [p]laintiff under a private writ to be seeking the right to office.”

And the Board “[was] not a claimant to the office of Constable.”

¶5. Approximately two months later, on May 7, 2018, the Board voted to remove Bailey

2 from office during an executive session.

¶6. On May 21, 2018, Bailey filed a bill of exceptions in the circuit court. He asserted

that his removal from office was unlawful and violated his constitutional right to due process.

He requested that the court vacate the Board’s decision and sought “general relief.”

Meanwhile, in July 2018, the Board passed and adopted a resolution authorizing and setting

a date for a special election. On August 6, 2018, Bailey filed his combined petition for a

temporary restraining order and a motion for a preliminary injunction in the circuit court. He

reasserted that he was unlawfully removed from office. He asked the court to enjoin the

Board from continuing with its decision to vacate the constable position, from interfering

with his capacity as a duly elected official, and from continuing with the special election.

He also requested “the payment for damages and costs sustained in light of the interference

with [his] duty to serve papers[;] court costs[;] attorney’s fees[;] and any compensatory

damages consistent with this court.”

¶7. After a telephonic hearing, the court entered an order on August 2, 2019. The court

found that Bailey’s bill of exceptions was untimely filed. And the court held, “It is therefore

ordered and adjudged that the relief sought in the Petition For Temporary Restraining Order

and Motion for Preliminary Injunction is denied and the present action is dismissed for lack

of jurisdiction.”

¶8. In his Appellant’s Brief, Bailey claims that the Board’s decision to remove him from

office without notice or a hearing violated his right to due process. He further claims that

3 the court erred by dismissing his bill of exceptions and denying injunctive relief. After the

initial briefing, this Court entered an order directing the parties to file supplemental briefs

addressing two issues:

1. Is the issue of injunctive relief moot because Carl Bailey’s term of office has expired?

2. If the issue of injunctive relief is moot, are there any remaining issues?

Bailey and the Board filed supplemental briefs in response to the Court’s order.

DISCUSSION

¶9. The circuit court did not reach the merits of Bailey’s due process claim. And this

Court does not consider matters that have not been decided by the trial court. Fidelity &

Deposit Co. of Maryland v. Ralph McKnight & Son Const. Inc., 28 So. 3d 1282, 1285 (¶14)

(Miss. 2010). Additionally, in his supplemental brief Bailey concedes that the issue of

injunctive relief is moot. This Court does not consider moot questions. Guyse v. State, 282

So. 3d 1287, 1289 (¶5) (Miss. Ct. App. 2019). Therefore, the sole issue before this Court is

whether the court erred by dismissing Bailey’s bill of exceptions for lack of jurisdiction.

¶10. It is well-established that jurisdictional issues and questions of law are reviewed de

novo. City of Jackson v. Allen, 242 So. 3d 8, 13 (¶17) (Miss. 2018).

¶11. Mississippi Code Annotated section 11-51-75 (Rev. 2012), which governs appeals

from decisions by municipal authorities, provided in part:

Any person aggrieved by a judgment or decision of the board of supervisors . . . may appeal within ten (10) days from the date of adjournment at which session the board of supervisors . . . rendered such judgment or decision, and

4 may embody the facts, judgment and decision in a bill of exceptions which shall be signed by the person acting as president of the board of supervisors . . . . The clerk thereof shall transmit the bill of exceptions to the circuit court at once, and the court shall either in term time or in vacation hear and determine the same on the case as presented by the bill of exceptions as an appellate court, and shall affirm or reverse the judgment.

Miss. Code Ann. § 11-51-75.1

¶12. With respect to the ten-day deadline set forth in section 11-51-75, our supreme court

has stated:

The ten-day statutory limit in which to appeal a decision rendered by municipal authorities is both mandatory and jurisdictional. Thence, when an appeal of a decision rendered by municipal authorities is not perfected within the statutory time constraint of ten days, no jurisdiction is conferred upon the appellate court, i.e., the circuit court.

City of Jackson v.

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Bluebook (online)
Carl Bailey, as a Constable of Western District of Jefferson County v. Jefferson County Board of Supervisors, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carl-bailey-as-a-constable-of-western-district-of-jefferson-county-v-missctapp-2021.