Carl Bailey, As a Constable of Western District of Jefferson County v. Jefferson County Board of Supervisors, James Wells, Cammie Hutherson, Jerry Wilson and SD Johnson, Jr.

CourtCourt of Appeals of Mississippi
DecidedSeptember 19, 2023
Docket2022-CP-00950-COA
StatusPublished

This text of Carl Bailey, As a Constable of Western District of Jefferson County v. Jefferson County Board of Supervisors, James Wells, Cammie Hutherson, Jerry Wilson and SD Johnson, Jr. (Carl Bailey, As a Constable of Western District of Jefferson County v. Jefferson County Board of Supervisors, James Wells, Cammie Hutherson, Jerry Wilson and SD Johnson, Jr.) 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, James Wells, Cammie Hutherson, Jerry Wilson and SD Johnson, Jr., (Mich. Ct. App. 2023).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2022-CP-00950-COA

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

v.

JEFFERSON COUNTY BOARD OF APPELLEES SUPERVISORS, JAMES WELLS, CAMMIE HUTHERSON, JERRY WILSON AND SD JOHNSON, JR.

DATE OF JUDGMENT: 08/08/2022 TRIAL JUDGE: HON. FORREST A. JOHNSON JR. COURT FROM WHICH APPEALED: JEFFERSON COUNTY CIRCUIT COURT ATTORNEY FOR APPELLANT: CARL BAILEY (PRO SE) ATTORNEY FOR APPELLEES: NICKITA SHANTA BANKS NATURE OF THE CASE: CIVIL - OTHER DISPOSITION: REVERSED, RENDERED, AND REMANDED - 09/19/2023 MOTION FOR REHEARING FILED:

BEFORE BARNES, C.J., GREENLEE AND EMFINGER, JJ.

BARNES, C.J., FOR THE COURT:

¶1. In 2021, this Court remanded this case to the Jefferson County Circuit Court for a

determination of whether the Jefferson County Board of Supervisors (Board) had improperly

removed Carl Bailey from his position as constable. Bailey v. Jefferson Cnty. Bd. of Sup’rs,

322 So. 3d 479, 483 (¶15) (Miss. Ct. App. 2021). The circuit court concluded that there was

not substantial evidence in the record “to support the [B]oard’s ultimate decision.” The court

further determined, however, that Bailey’s “claim for relief or damages is no longer viable.”

¶2. Bailey appeals the circuit court’s ruling on damages. Based on the Mississippi Supreme Court’s decision in City of Durant v. Laws Construction Co., 721 So. 2d 598 (Miss.

1998), we find that damages would be an appropriate remedy in this instance. We reverse

the court’s judgment, render judgment in favor of Bailey, and remand for a hearing and

ruling on damages.

FACTS AND PROCEDURAL HISTORY

¶3. After it was alleged that Bailey, the constable for the western district of Jefferson

County, had moved out of his district, the county administrator sent Bailey a letter dated

November 23, 2016, informing him “that his move had violated election laws and requested

his appearance at the next scheduled board meeting on December 5, 2016.” Bailey, 322 So.

3d at 480 (¶2). “In September 2017, the Board filed a complaint for writ of quo warranto in

the circuit court, . . . assert[ing] that Bailey continued to act as constable, preventing the

Board from filling the position or calling a special election.” Id. at (¶3). On March 8, 2018,

the circuit court dismissed the complaint without prejudice because the Board’s complaint

for a public writ “had not been brought by a proper party for the State—the district attorney

or Attorney General.” Id. at 481 (¶4).

¶4. On May 7, 2018, the Board voted during an executive session to remove Bailey as

constable. Id. at (¶5). Bailey appealed by filing a bill of exceptions with the circuit court on

May 21, 2018, claiming that his removal “was unlawful and violated his constitutional right

to due process.”1 Id. at (¶6). Seeking “general relief,” Bailey asked that the court vacate the

1 See Miss. Code Ann. § 11-51-75 (Rev. 2012) (providing that “[a]ny person aggrieved by a judgment or decision of the board of supervisors [of a county] . . . may appeal . . . [the] judgment or decision . . . [by] a bill of exceptions to the circuit court . . . .”).

2 Board’s decision. Id. The Board meanwhile set a date for a special election. Id. “On

August 6, 2018, Bailey filed a combined petition for a temporary restraining order and a

motion for a preliminary injunction in the circuit court,” reasserting his claim “that he was

unlawfully removed from office.” Id. Bailey requested that the court “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.” Id. He

also sought “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.” Id. On August 2, 2019, the circuit court found that Bailey’s bill of

exceptions was untimely filed under Mississippi Code Annotated section 11-51-75 (Rev.

2012) and dismissed the action.2 Id. at (¶7).

¶5. On appeal, this Court concluded that although Bailey’s bill of exceptions was

untimely filed, the circuit court’s dismissal on the basis of jurisdiction was erroneous because

the Board had failed to provide Bailey with “sufficient notice” of the proceeding. Id. at 482

(¶¶13-14). We remanded to the circuit court for a determination of “whether Bailey ha[d]

preserved any claim for relief or damages, including whether he was eligible to serve in his

prior elected office because of his residency.” Id. at 483 (¶15).

¶6. In its “Order Upon Remand,” the circuit court found that the record did not contain

substantial evidence to support the Board’s decision to remove Bailey from his position as

2 Section 11-51-75 required a person to “appeal within ten (10) days from the date of adjournment at which session the board . . . rendered such judgment or decision . . . .”

3 constable. Yet the court declined to award damages, stating “that any further claim for relief

or damages is no longer viable.” On June 24, 2022, Bailey filed an omnibus motion to

amend the findings or for relief from the judgment, arguing that he should be awarded

compensatory damages. The court denied Bailey’s motion, stating that “[t]o address the issue

of damages on the full record before the court as it is would be speculative and without

sufficient evidentiary basis to do so.” Bailey appeals from the court’s judgment, claiming

that he is entitled to damages.

DISCUSSION

¶7. The sole issue on appeal is whether the circuit court erred in finding that Bailey was

not entitled to damages as a result of the Board’s removal of him from office without proper

notice. The Board has not filed an appellee’s brief. The Mississippi Supreme Court has

adopted two approaches in reviewing cases where the appellee has failed to file a brief.

“First, the Court may ‘accept appellant’s brief as confessed and reverse.’” Stratton v.

McKey, 298 So. 3d 999, 1003 (¶11) (Miss. 2020) (quoting May v. May, 297 So. 2d 912, 913

(Miss. 1974)). This course of action is appropriate “when the record is voluminous or

complicated and the appellant’s thorough treatment of the issues in the brief makes out an

apparent case of error.” Id. (internal quotation marks omitted). “The second alternative is

to disregard the appellees’ error and affirm.” Id. (quoting Miller v. Pannell, 815 So. 2d 1117,

1119 (¶7) (Miss. 2002)). “This alternative should be used when the record can be

conveniently examined and such examination reveals a sound and unmistakable basis or

ground upon which the judgment may be safely affirmed.” Id. (quoting Miller, 815 So. 2d

4 at 1119 (¶7)).

¶8. Although the record in this case is neither complicated nor voluminous, we

nevertheless take the Board’s failure to file an appellee’s brief under the circumstances as

a confession of error with regard to its decision to remove Bailey from office. Moreover, we

find that Bailey has established apparent error as to the circuit court’s failure to consider

damages in this instance.

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Related

May v. May
297 So. 2d 912 (Mississippi Supreme Court, 1974)
Preferred Transport Co. v. Claiborne County Board of Supervisors
32 So. 3d 549 (Court of Appeals of Mississippi, 2010)
Miller v. Pannell
815 So. 2d 1117 (Mississippi Supreme Court, 2002)
In Re Broome
815 So. 2d 1 (Supreme Court of Louisiana, 2002)
City of Durant v. Laws Const. Co., Inc.
721 So. 2d 598 (Mississippi Supreme Court, 1998)
Peggy P. McGrew v. Charles Elliot McGrew
184 So. 3d 302 (Court of Appeals of Mississippi, 2015)
W.G. Yates & Sons Construction Co. v. City of Waveland
168 So. 3d 963 (Court of Appeals of Mississippi, 2012)

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Bluebook (online)
Carl Bailey, As a Constable of Western District of Jefferson County v. Jefferson County Board of Supervisors, James Wells, Cammie Hutherson, Jerry Wilson and SD Johnson, Jr., Counsel Stack Legal Research, https://law.counselstack.com/opinion/carl-bailey-as-a-constable-of-western-district-of-jefferson-county-v-missctapp-2023.