Chamberlain v. Baxter

CourtDistrict Court, N.D. Mississippi
DecidedJune 28, 2023
Docket4:21-cv-00170
StatusUnknown

This text of Chamberlain v. Baxter (Chamberlain v. Baxter) is published on Counsel Stack Legal Research, covering District Court, N.D. Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Chamberlain v. Baxter, (N.D. Miss. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF MISSISSIPPI GREENVILLE DIVISION

MICHAEL CHAMBERLAIN and TONYA CHAMBERLAIN INDIVIDUALLY, AND ON BEHALF OF THE ESTATE AND WRONGFUL DEATH HEIRS AT LAW OF AUSTIN HUNTER CHAMBERLAIN, DECEASED PLAINTIFFS

V. CIVIL ACTION NO. 4:21-CV-170-SA-JMV

DRY DOCK BAR & GRILL, INC., JC RENTALS, INC., CHARLES MARTER, PATRICIA RICHARDSON, and JOHN/JANE DOES 1-10 DEFENDANTS

ORDER AND MEMORANDUM OPINION On December 20, 2021, Michael Chamberlain and Tonya Chamberlain, individually and on behalf of the estate and wrongful death heirs at law of Austin Hunter Chamberlain (“the Plaintiffs”) initiated this civil action by filing their Complaint [1]. Now before the Court are three separate Motions: Charles Marter’s Motion for Summary Judgment [134]; Patricia Richardson’s Motion for Summary Judgment [136]; and JC Rentals, Inc.’s Motion for Summary Judgment [138]. All three Motions [134, 136, 138] are ripe for review. Having reviewed the filings, as well as the applicable authorities, the Court is prepared to rule. Relevant Background The underlying events from which this lawsuit stems occurred on the night of October 23, 2021 and into the following morning. Austin Hunter Chamberlain and Maxley Baxter visited Dry Dock Bar & Grill located in Grenada County, Mississippi. At the time, Chamberlain and Baxter were both nineteen years old. Chamberlain and Baxter apparently spent several hours at Dry Dock and, while there, both consumed alcohol. Eventually, they left the establishment in a vehicle with Baxter driving. The vehicle was owned by Baxter’s stepfather, David Hoglund. At approximately 2:00 AM, Chamberlain and Baxter had a wreck when the vehicle left a curved, two-lane road and collided with multiple trees. Chamberlain was ejected from the vehicle and ultimately died. An alcohol blood test was administered on Baxter, yielding a .26 BAC result. He later pled guilty to aggravated vehicular homicide and received a sentence of 20 years with 14 years suspended—he is currently incarcerated.

As of October 2021, the real property on which Dry Dock operates was owned by JC Rentals. In January 2022 (around three months after the accident occurred), the property was conveyed to Dry Dock via a deed recorded in the Grenada County land records. Patricia Richardson and Charles Marter are the two managers/members of JC Rentals, and JC Rentals’ operating agreement indicates that they each possess a 50 percent interest in the entity. Similarly, Richardson and Marter were (and still are) the sole members of Dry Dock. For further context, Marter is Baxter’s grandfather. The Plaintiffs brought suit against Baxter, Hoglund, Dry Dock, JC Rentals, Richardson, and Marter. In the Amended Complaint [14], they assert a claim against Baxter for negligent

operation of a motor vehicle and against Hoglund for negligent entrustment. On March 20, 2023, this Court entered an Agreed Order of Dismissal with Prejudice [125] as to Baxter and Hoglund. They are no longer Defendants in this case. Thus, the remaining Defendants are Dry Dock, JC Rentals, Richardson, and Marter. Against those Defendants, the Plaintiffs assert claims for dram shop liability, negligence per se, attractive nuisance, and gross negligence. JC Rentals, Richardson, and Marter have each filed separate requests for dismissal of the claims asserted against them. Summary Judgment Standard Summary judgment is warranted when the evidence reveals no genuine dispute regarding any material fact, and the moving party is entitled to judgment as a matter of law. FED. R. CIV. P. 56(a). Rule 56 “mandates the entry of summary judgment, after adequate time for discovery and upon motion, against a party who fails to make a showing sufficient to establish the existence of

an element essential to that party’s case, and on which that party will bear the burden of proof at trial.” Nabors v. Malone, 2019 WL 2617240, at *1 (N.D. Miss. June 26, 2019) (quoting Celotex Corp. v. Catrett, 477 U.S. 317, 322, 106 S. Ct. 2548, 91 L. Ed. 2d 265 (1986)). “The moving party ‘bears the initial responsibility of informing the district court of the basis for its motion, and identifying those portions of the record which it believes demonstrate the absence of a genuine issue of material fact.’” Id. (quoting Celotex, 477 U.S. at 323). “The nonmoving party must then ‘go beyond the pleadings’ and ‘designate specific facts showing that there is a genuine issue for trial.’” Id. (quoting Celotex, 477 U.S. at 324). Importantly, “the inferences to be drawn from the underlying facts contained in the affidavits, depositions, and

exhibits of record must be viewed in the light most favorable to the party opposing the motion.” Waste Mgmt. of La., LLC v. River Birch, Inc., 920 F.3d 958, 964 (5th Cir. 2019) (quoting Reingold v. Swiftships, Inc., 126 F.3d 645, 646 (5th Cir. 1997)). However, “[c]onclusory allegations, speculation, unsubstantiated assertions, and legalistic arguments are not an adequate substitute for specific facts showing a genuine issue for trial.” Nabors, 2019 WL 2617240 at *1 (citing TIG Ins. Co. v. Sedgewick James of Wash., 276 F.3d 754, 759 (5th Cir. 2002)) (additional citations omitted). Analysis and Discussion As noted above, the Plaintiffs assert claims against Dry Dock, JC Rentals, Richardson, and Marter for dram shop liability, negligence per se, attractive nuisance, and gross negligence. The present Motions [134, 136, 138] do not necessarily concern the merits of those claims but instead relate to whether JC Rentals, Richardson, and/or Marter are proper Defendants as to those claims. More specifically, Richardson and Marter argue that there is no basis for them to be held liable simply because of their status as LLC members. For its part, JC Rentals contends that it is an entity existing completely separate and independent of Dry Dock and therefore cannot be held liable for

the underlying conduct of Dry Dock. Prior to addressing the merits of the Motions [134, 136, 138], the Court will briefly address one issue associated with the corporate structure of both Dry Dock and JC Rentals. Both entities were initially formed as LLCs. However, both entities were erroneously converted to corporations in April 2021. In an affidavit, Marter provided the following information: As we explained in our depositions, our accountant Carrie Vincent intended to file an annual report for Dry Dock, LLC with the Mississippi Secretary of State in April 2021. Inadvertently, instead of filing an annual report, Ms. Vincent filed a document which converted Dry Dock, LLC to a corporation, Dry Dock, Inc. This was unknown to me or Patricia Richardson until it was discovered in December 2021, at which time Ms. Vincent converted Dry Dock back to a limited liability company, Dry Dock, LLC. Our attorneys have been fully transparent with this information, and I have previously testified to this.

[134], Ex. 8 at p. 2. Similarly, acting as JC Rentals’ designee for its Rule 30(b)(6) deposition, Richardson testified that Vincent made the same mistake in connection with JC Rentals’ status in April 2021 and that the entity was converted back to an LLC in December 2021. See [138], Ex. 6 at p. 3. Thus, although both entities were technically corporations as of October 2021, they have at all times operated as LLCs.

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Bluebook (online)
Chamberlain v. Baxter, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chamberlain-v-baxter-msnd-2023.