Cody Patterson and Corey Patterson, Individually and on Behalf of the Wrongful Death Beneficiaries of Johnny Patterson v. State of Mississippi, ex rel. Attorney General Lynn Fitch and Mississippi Department of Transportation

CourtMississippi Supreme Court
DecidedSeptember 11, 2025
Docket2024-CA-00788-SCT
StatusPublished

This text of Cody Patterson and Corey Patterson, Individually and on Behalf of the Wrongful Death Beneficiaries of Johnny Patterson v. State of Mississippi, ex rel. Attorney General Lynn Fitch and Mississippi Department of Transportation (Cody Patterson and Corey Patterson, Individually and on Behalf of the Wrongful Death Beneficiaries of Johnny Patterson v. State of Mississippi, ex rel. Attorney General Lynn Fitch and Mississippi Department of Transportation) is published on Counsel Stack Legal Research, covering Mississippi Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Cody Patterson and Corey Patterson, Individually and on Behalf of the Wrongful Death Beneficiaries of Johnny Patterson v. State of Mississippi, ex rel. Attorney General Lynn Fitch and Mississippi Department of Transportation, (Mich. 2025).

Opinion

IN THE SUPREME COURT OF MISSISSIPPI

NO. 2024-CA-00788-SCT

CODY PATTERSON AND COREY PATTERSON, INDIVIDUALLY AND ON BEHALF OF THE WRONGFUL DEATH BENEFICIARIES OF JOHNNY PATTERSON

v.

STATE OF MISSISSIPPI, EX REL. ATTORNEY GENERAL LYNN FITCH AND MISSISSIPPI DEPARTMENT OF TRANSPORTATION

DATE OF JUDGMENT: 06/12/2024 TRIAL JUDGE: HON. PAUL S. FUNDERBURK TRIAL COURT ATTORNEYS: GARY L. CARNATHAN MARGARET SAMS GRATZ THOMAS ORVILLE COOLEY CHRIS H. DEATON LINDSAY THOMAS DOWDLE COURT FROM WHICH APPEALED: LEE COUNTY CIRCUIT COURT ATTORNEY FOR APPELLANTS: THOMAS ORVILLE COOLEY ATTORNEYS FOR APPELLEES: OFFICE OF THE ATTORNEY GENERAL BY: LINDSAY THOMAS DOWDLE JUSTIN L. MATHENY CHRIS H. DEATON NATURE OF THE CASE: CIVIL - WRONGFUL DEATH DISPOSITION: AFFIRMED - 09/11/2025 MOTION FOR REHEARING FILED:

BEFORE KING, P.J., ISHEE AND SULLIVAN, JJ.

SULLIVAN, JUSTICE, FOR THE COURT:

¶1. Johnny Patterson was struck and killed by a vehicle while acting within the course and

scope of his employment as a school resource officer. Allegedly, the accident was the result,

in part, of an inoperable warning sign on a roadway maintained by the Mississippi Department of Transportation (MDOT). In response, Patterson’s two adult sons, Cody and

Corey Patterson, filed an action against the MDOT for the negligent, wrongful death of their

father. MDOT moved for summary judgment, seeking immunity under the Mississippi Tort

Claims Act (MTCA). MDOT claimed that as a state-government entity, it was immune from

suit because Patterson’s employer, Lee County School District, had paid workers’

compensation benefits and was another state-government entity. The sons disagreed. They

argued also that, if MDOT was immune, then Mississippi Code Section 11-46-9(1)(l) (Rev.

2019) violated the state and federal constitutions.

¶2. The trial court granted MDOT’s motion for summary judgment and denied the sons’

motion challenging the constitutionality of Section 11-46-9(1)(l). On appeal, the sons argue

that (1) Section 11-46-9(1)(l) is inapplicable, and (2) if MDOT is immune, Section 11-46-

9(1)(l) is unconstitutional.

¶3. We find that the requirements for immunity under Section 11-46-9(1)(l) were

satisfied, meaning the trial court correctly determined that MDOT was entitled to immunity.

We find also that the statute passes constitutional muster. Thus, we affirm the trial court’s

orders.

FACTS

¶4. On January 13, 2022, Patterson, a school resource officer for the Lee County School

District, was directing traffic on Highway 45. In addition to the normal posted speed limit

of sixty-five miles per hour, the northbound portion of Highway 45 displayed a school zone

sign equipped with lights to warn motorists to decrease speed to forty-five miles per hour

2 when the lights were flashing. As the school was dismissing for the day, a motorist, who was

driving northbound and over the posted speed limit, collided with the back of Patterson’s car,

which had been parked in the roadway to help direct traffic. The collision resulted in

Patterson’s being struck by his vehicle and severely injured. Patterson was taken to a

hospital, where he died a few days later.

¶5. Patterson was survived by his wife and two sons. His wife received workers’

compensation benefits through Patterson’s employer, Lee County School District. But his

two adult sons did not receive any workers’ compensation benefits.

¶6. On January 11, 2023, Patterson’s sons filed a negligence claim against MDOT,

alleging that it had failed to maintain, inspect, and repair the traffic signal and that it had

failed to warn of a dangerous condition.1 Specifically, the sons claimed that the traffic light

had failed to flash and to warn motorists of the upcoming speed and school zone. The sons

sought damages for their own pain and suffering, emotional and mental distress, and loss of

society and companionship.

¶7. On March 6, 2023, MDOT filed a motion for summary judgment, asserting immunity

under Section 11-46-9(1)(l).2 MDOT alleged that Section 11-46-9(1)(l) provides immunity

1 The sons also asserted claims against (1) Lee County, Mississippi, (2) the Mississippi Department of Public Safety (MDPS), and (3) John Does 1-10. On February 1, 2023, the sons voluntarily dismissed their claims against MDPS without prejudice. On June 5, 2023, the parties entered into an agreed order to dismiss Lee County from the case without prejudice. 2 MDOT asserted also that the trial court should grant its motion for summary judgment based on the exclusive-remedy provision of Mississippi’s Workers’ Compensation Law. See Miss. Code Ann. § 71-3-9 (Rev. 2021).

3 to all state government entities (MDOT) if the employee of any state governmental entity (Patterson) is injured in the course and scope of his employment and the state governmental entity for which the injured employee worked at the time of injury (Lee County School District) provides worker’s compensation benefits for the injury.

MDOT argued that Section 11-46-9(1)(l) applies to claims brought by the wrongful-death

beneficiaries of a governmental employee based on this Court’s analysis of a similar MTCA

immunity provision, Mississippi Code Section 11-46-9(1)(m) (Rev. 2019). MDOT asserted

that “[i]f the ‘plain language’ of 11-46-9(1)(m) bars the claims of the wrongful death

beneficiaries of an ‘inmate,’ then so [too] does the plain language of 11-46-9(1)(l) bar the

claims of the wrongful death beneficiaries of an ‘employee.’”

¶8. The sons disagreed with MDOT’s statutory interpretation, asserting that “the statutory

immunity asserted does not apply to the injured employee’s wrongful death beneficiaries”

as “[n]othing in the plain wording of the statute suggests, as MDOT argues, that the

exemption applies to anyone other than the injured employee.” They explained that “[u]nder

the plain and unambiguous wording of the statute, the ‘claimant’ would be [the sons], and

here, neither son is an ‘employee’ of a governmental entity.”

¶9. The sons argued also that granting MDOT’s motion on the basis of immunity would

violate their “rights as afforded to them under the Mississippi Constitution and the United

States Constitution.” They claimed that

[T]he application of Section 11-46-9(1)(l) advanced by MDOT precludes [the sons] from any remedy under the law, and it does not afford them the same rights they would have if their father had worked in the private sector or if their father’s death was linked to a private entity’s negligence.

4 In addition to violating the Mississippi Constitution, the sons argued, MDOT’s application

of Section 11-46-9(1)(l) would violate the Equal Protection Clause of the Fourteenth

Amendment to the United States Constitution as it creates “arbitrary distinctions and unequal

treatment.”

¶10. On August 17, 2023, the Attorney General of Mississippi filed an unopposed motion

for leave to intervene as a nonaligned party to address the constitutionality of Section

11-46-9(1)(l). The motion was granted on August 22, 2023. The attorney general asserted

that the sons cannot show beyond a reasonable doubt that the statute is unconstitutional. It

argued that (1) no evidence demonstrated that the statute violated the remedies provision of

the Mississippi Constitution, (2) no due-process violation occurred because there is no

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Cody Patterson and Corey Patterson, Individually and on Behalf of the Wrongful Death Beneficiaries of Johnny Patterson v. State of Mississippi, ex rel. Attorney General Lynn Fitch and Mississippi Department of Transportation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cody-patterson-and-corey-patterson-individually-and-on-behalf-of-the-miss-2025.