Chaquita S. Dobbs v. City of Columbus, Mississippi and Dalton T. Conwill, in his official capacity as a City of Columbus Police Office

CourtCourt of Appeals of Mississippi
DecidedDecember 10, 2019
DocketNO. 2018-CA-01636-COA
StatusPublished

This text of Chaquita S. Dobbs v. City of Columbus, Mississippi and Dalton T. Conwill, in his official capacity as a City of Columbus Police Office (Chaquita S. Dobbs v. City of Columbus, Mississippi and Dalton T. Conwill, in his official capacity as a City of Columbus Police Office) 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
Chaquita S. Dobbs v. City of Columbus, Mississippi and Dalton T. Conwill, in his official capacity as a City of Columbus Police Office, (Mich. Ct. App. 2019).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2018-CA-01636-COA

CHAQUITA S. DOBBS APPELLANT

v.

CITY OF COLUMBUS, MISSISSIPPI AND APPELLEES DALTON T. CONWILL, IN HIS OFFICIAL CAPACITY AS A CITY OF COLUMBUS POLICE OFFICER

DATE OF JUDGMENT: 11/01/2018 TRIAL JUDGE: HON. LEE SORRELS COLEMAN COURT FROM WHICH APPEALED: LOWNDES COUNTY CIRCUIT COURT ATTORNEY FOR APPELLANT: BARBARA W. CLARK ATTORNEY FOR APPELLEES: KATHERINE S. KERBY NATURE OF THE CASE: CIVIL - PERSONAL INJURY DISPOSITION: AFFIRMED - 12/10/2019 MOTION FOR REHEARING FILED: MANDATE ISSUED:

BEFORE BARNES, C.J., McCARTY AND C. WILSON, JJ.

C. WILSON, J., FOR THE COURT:

¶1. This is a Mississippi Tort Claims Act (MTCA) case. The case arises from a two-car

automobile accident between Chaquita Dobbs and City of Columbus police officer Dalton

Conwill. Following the accident, Dobbs sued the City of Columbus, Mississippi (city) and

Conwill in his official capacity as a city police officer. The circuit court dismissed the action

because Dobbs failed to comply with the statutory notice requirements of Mississippi Code

Annotated section 11-46-11 (Rev. 2012). Dobbs now appeals, alleging (1) that she

substantially complied with the statute, (2) that the city waived the statutory pre-suit notice

requirement, and (3) that she should have been allowed to conduct discovery prior to dismissal. We find that strict compliance with section 11-46-11 is necessary, and the circuit

court did not err. We therefore affirm.

FACTS AND PROCEDURAL HISTORY

¶2. On May 16, 2017, Dobbs and Conwill were in a two-car automobile accident.

Conwill, who was on duty as a city police officer at the time of the accident, allegedly

crossed the centerline, hitting Dobbs head on.

¶3. Ten days later, Travelers, the city’s automobile-liability insurance carrier, sent Dobbs

a letter. In the letter, Travelers acknowledged that it had received an accident report and that

it was investigating responsibility. On June 8, 2017, Travelers sent Dobbs a second letter.

In the second letter, Travelers “acknowledged receipt” of claim number E7C2905—

Claimant: Chaquita Dobbs, Insured: City of Columbus—but stated that it was denying the

claim. Travelers explained,

With respect to claims arising out of police and fire protection activities, the [MTCA] generally provides for the imposition of liability only in instances where the governmental employee acted in reckless disregard for the safety and well-being of others. The investigation here did not reveal that Dalton Conwill acted in an intentional, willful or otherwise reckless manner, and therefore there does not appear to be any evidence of reckless disregard in this instance. As such, it is our position that the City of Columbus and Dalton Conwill are not liable for the accident in question or any alleged damages resulting from same.

¶4. On November 16, 2017, Dobbs’s attorney mailed a “Notice of Claim,” via certified

mail, to the city’s chief operations officer (COO), David Armstrong. In the letter, Dobbs’s

attorney stated that the May 16 accident resulted in a total loss of Dobbs’s vehicle and severe

personal injuries to Dobbs. She also alleged that the accident resulted from Conwill’s gross

2 negligence and demanded $75,000 to settle Dobbs’s claim against the city. On February 1,

2018, Travelers sent a response letter to Dobbs’s attorney. In the letter, which was verbatim

of the June 8, 2017 letter sent to Dobbs, Travelers again acknowledged receipt of claim

number E7C2905, arising from the May 16, 2017 accident, and again Travelers stated it was

denying the claim.

¶5. On May 11, 2018, Dobbs filed the subject action. Rather than filing an answer, the

city filed a motion to dismiss.1 In its motion, the city contended that dismissal should be

granted because Dobbs did not serve pre-suit notice on the statutorily mandated

recipient—the city clerk or the mayor—pursuant to Mississippi Code Annotated section 11-

46-11(2)(a). Dobbs filed a response in opposition. Following a hearing on the motion, the

circuit court entered an order of dismissal, granting the city’s motion. Dobbs now appeals.

¶6. On appeal, Dobbs raises three issues: (1) whether the pre-suit notice that Dobbs sent

to the city’s COO substantially complied with section 11-46-11; (2) whether the city waived

the pre-suit notice required by section 11-46-11 when its insurer made initial contact with

Dobbs regarding its claim investigation and denial; and (3) whether the circuit court erred

in dismissing Dobbs’s claim without allowing her to conduct discovery to determine if the

city had actual notice of her claim. We address these issues in turn.

STANDARD OF REVIEW

1 The city filed its motion to dismiss pursuant to Mississippi Rule of Civil Procedure 12(b)(1) for lack of jurisdiction, Rule 12(b)(4) for deficient process, Rule 12(b)(5) for insufficiency of service of process, Rule 12(b)(6) for failure to state a claim upon which relief may be granted for defective service of pre-suit tort notice and for deficient service of process, and Rule 12(h)(3) for lack of jurisdiction.

3 ¶7. “When considering a motion to dismiss, this Court’s standard of review is de novo.”

Scaggs v. GPCH-GP Inc., 931 So. 2d 1274, 1275 (¶6) (Miss. 2006). “This Court will not

disturb the findings of the trial court unless they are manifestly wrong, clearly erroneous or

an erroneous legal standard was applied.” Id. We also review questions of law, including

statutory interpretation and the proper application of the MTCA, de novo. Arceo v. Tolliver,

19 So. 3d 67, 70 (¶9) (Miss. 2009); Fairley v. George County, 871 So. 2d 713, 716 (¶7)

(Miss. 2004).

DISCUSSION

¶8. Dobbs’s complaint, which asserts tort claims against Conwill in his official capacity

as a city police officer, falls under the MTCA. “The MTCA provides immunity for the

alleged torts of governmental entities[; but it] waives that immunity, and the governmental

entity is liable, for injuries caused by the entity or its employees while acting in the course

and scope of their employment.” Zumwalt v. Jones Cty. Bd. of Sup’rs, 19 So. 3d 672, 688

(¶82) (Miss. 2009).

¶9. To file an MTCA action, a party must comply with the statute’s notice requirement,

which in relevant part, provides as follows:

(1) After all procedures within a governmental entity have been exhausted, any person having a claim under this chapter shall proceed as he might in any action at law or in equity, except that at least ninety (90) days before instituting suit, the person must file a notice of claim with the chief executive officer of the governmental entity.

(2)(a) Service of notice of claim shall be made as follows: (i) For local governments: 1. If the governmental entity is a county, then upon the chancery clerk of the county sued;

4 2. If the governmental entity is a municipality, then upon the city clerk. . . .

Miss. Code Ann. § 11-46-11 (emphasis added). Because Dobbs intended to file an MTCA

action against a municipality, she had to serve a notice of claim upon the chief executive

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Related

Ferrer v. Jackson County Bd. of Sup'rs
741 So. 2d 216 (Mississippi Supreme Court, 1999)
Scaggs v. GPCH-GP, INC.
931 So. 2d 1274 (Mississippi Supreme Court, 2006)
Arceo v. Tolliver
19 So. 3d 67 (Mississippi Supreme Court, 2009)
Fairley v. George County
871 So. 2d 713 (Mississippi Supreme Court, 2004)
University Medical Center v. Easterling
928 So. 2d 815 (Mississippi Supreme Court, 2006)
Tallahatchie General Hospital v. Howe
49 So. 3d 86 (Mississippi Supreme Court, 2010)
Zumwalt v. Jones County Board of Supervisors
19 So. 3d 672 (Mississippi Supreme Court, 2009)

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Chaquita S. Dobbs v. City of Columbus, Mississippi and Dalton T. Conwill, in his official capacity as a City of Columbus Police Office, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chaquita-s-dobbs-v-city-of-columbus-mississippi-and-dalton-t-conwill-missctapp-2019.