Cynthia McNair v. J.F.M., Inc.

CourtCourt of Appeals of Mississippi
DecidedJuly 27, 2021
Docket2020-CA-00342-COA
StatusPublished

This text of Cynthia McNair v. J.F.M., Inc. (Cynthia McNair v. J.F.M., Inc.) 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
Cynthia McNair v. J.F.M., Inc., (Mich. Ct. App. 2021).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2020-CA-00342-COA

CYNTHIA McNAIR APPELLANT

v.

J.F.M., INC. APPELLEE

DATE OF JUDGMENT: 02/21/2020 TRIAL JUDGE: HON. ROBERT B. HELFRICH COURT FROM WHICH APPEALED: FORREST COUNTY CIRCUIT COURT ATTORNEY FOR APPELLANT: VANESSA J. JONES ATTORNEYS FOR APPELLEE: WILLIAM HARRY ECKERT ROY A. NOWELL JR. MICHAEL J. TARLETON NATURE OF THE CASE: CIVIL - PERSONAL INJURY DISPOSITION: AFFIRMED - 07/27/2021 MOTION FOR REHEARING FILED: MANDATE ISSUED:

BEFORE BARNES, C.J., WESTBROOKS AND SMITH, JJ.

BARNES, C.J., FOR THE COURT:

¶1. This appeal stems from a premises liability case filed by Cynthia McNair against

J.F.M., Inc., related to a “slip and fall” at a Junior Food Mart convenience store in

Hattiesburg, Mississippi. McNair appeals the trial court’s grant of J.F.M.’s motion to

dismiss her complaint with prejudice because it was not filed within the statute of

limitations. Finding no error, we affirm.

STATEMENT OF FACTS AND PROCEDURAL HISTORY

¶2. The following facts are the only ones in the scarce record before the Court.1 On

1 The record includes twenty-eight pages of court documents and an eight-page transcript. November 6, 2014, when McNair was shopping at a Junior Food Mart convenience store

on West 7th Street in Hattiesburg, Mississippi, she slipped on a large puddle of standing

water and fell, injuring her neck and back. McNair filed an initial complaint, which is not

at issue in this appeal, against J.F.M. on October 24, 2017, in the Forrest County Circuit

Court, thirteen days before the three-year statute of limitations expired. Due to improper

service of process, J.F.M. ultimately moved to dismiss the complaint with prejudice.2

¶3. On August 15, 2019, the judge signed an order of dismissal without prejudice due to

McNair’s failure to serve process properly or show good cause why J.F.M. was not served

within 120 days under Mississippi Rule of Civil Procedure 4(h). The order was filed with

the circuit court clerk the next day. McNair’s counsel, however, stated she did not receive

the order until August 26, 2019, via the United States Postal Service.3

¶4. On September 5, 2019, McNair refiled her complaint. On November 5, 2019, J.F.M.

was properly served with process containing the second complaint. On November 27, 2019,

J.F.M. filed a motion to dismiss McNair’s second complaint with prejudice, claiming the

action was barred by the statute of limitations. J.F.M. explained that when McNair filed her

initial complaint on October 24, 2017, there were thirteen days remaining before the three-

2 In a motion to dismiss under Rule 12(b)(6), “the allegations in the complaint must be taken as true.” Covington Cnty. Bank v. Magee, 177 So. 3d 826, 828 (¶5) (Miss. 2015). 3 The facts and pleadings related to the initial complaint are somewhat relevant to the issues before the Court, but they are not on appeal. The initial summons, complaint, and order of dismissal are listed as exhibits to J.F.M.’s motion to dismiss the current action, but they were not attached to the motion in this Court’s or the circuit court’s record. McNair, however, admits to the accuracy of these documents, dates, and reason for dismissal of the initial complaint in her response to the current motion to dismiss.

2 year statute of limitations expired; therefore, J.F.M. argued McNair had thirteen days from

August 16, 2019, to refile her complaint before the statute of limitations expired on August

29, 2019. J.F.M. claimed McNair’s second complaint, filed on September 5, 2019, was at

least seven days late. McNair, however, responded that the statute of limitations did not

begin to run again until August 26, 2019, when her counsel received by mail the order

setting aside the first complaint.

¶5. A hearing on the motion was held before Judge Robert Helfrich, a different judge

than the one who heard the proceedings on the initial complaint. In February 2020, Judge

Helfrich agreed with J.F.M., finding the second complaint was not filed within the statute

of limitations and dismissed the second complaint with prejudice. McNair now appeals.

ANALYSIS

¶6. The relevant issue before this Court is whether the statute of limitations ran before

the filing of McNair’s second complaint. McNair, however, does not raise this issue in her

opening brief but instead addresses it in her reply brief in response to J.F.M.’s arguments.

In her opening brief, McNair focuses on issues related to the initial complaint, which is not

before us. Accordingly, we shall discuss the propriety of the dismissal of the second

complaint and then summarily address McNair’s arguments related to the initial complaint.

¶7. This Court’s standard of review is as follows: “The [circuit] court’s grant of a motion

to dismiss based upon the statute of limitations presents a question of law to which this

Court applies de novo review.” Anderson v. R & D Foods Inc., 913 So. 2d 394, 397 (¶7)

(Miss. Ct. App. 2005).

3 I. Statute of Limitations

¶8. When McNair filed her initial complaint on October 24, 2017, based on the incident

on November 6, 2014, there were thirteen days left before the statute of limitations expired.

The filing of the complaint tolled the statute of limitations. J.F.M. asserts that at the latest,

the statute of limitations remained tolled until the date the order of dismissal was entered,

or August 16, 2019, and expired thirteen days later on August 29, 2019, before the second

complaint was filed on September 5, 2019. In contrast, McNair argues that the statute of

limitations remained tolled until August 26, 2019, when her counsel received the order of

dismissal, and thus, her second complaint was filed before the statute of limitations expired

on September 9, 2019. Both calculations are incorrect.

¶9. The statute of limitations for a negligence claim in Mississippi is three years. See

Miss. Code Ann. § 15-1-49 (Rev. 2019). “The filing of an action tolls the statute of

limitations until the expiration of the 120-day service period.” Triple C Transport Inc. v.

Dickens, 870 So. 2d 1195, 1199 (¶32) (Miss. 2004) (quoting Watters v. Stripling, 675 So.

2d 1242, 1244 (Miss. 1996)). However, if “the plaintiff fails to serve process on the

defendant within that 120-day period, the statute of limitations automatically begins to run

again when that period expires.” Id. at 1200 (¶34) (quoting Holmes v. Coast Transit Auth.,

815 So. 2d 1183, 1185 (¶7) (Miss. 2002)). “In order to further toll the statute of limitations,

the plaintiff must . . . refile the complaint before the statute of limitations ends, or show good

cause for failing to serve process on the defendant within that 120-day period; otherwise,

4 dismissal is proper.”4 Id.

¶10. Under Triple C, Mississippi law is clear that once the initial complaint was filed, the

statute of limitations was tolled for 120 days. However, McNair did not properly serve

J.F.M. with her initial complaint; therefore, the statute of limitations automatically began to

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Related

Shelton v. Kindred
279 So. 2d 642 (Mississippi Supreme Court, 1973)
Holmes v. Coast Transit Authority
815 So. 2d 1183 (Mississippi Supreme Court, 2002)
Watters v. Stripling
675 So. 2d 1242 (Mississippi Supreme Court, 1996)
Triple" C" Transport, Inc. v. Dickens
870 So. 2d 1195 (Mississippi Supreme Court, 2004)
Anderson v. R & D FOODS, INC.
913 So. 2d 394 (Court of Appeals of Mississippi, 2005)
Lewis Entertainment, Inc. v. Brady
142 So. 3d 396 (Mississippi Supreme Court, 2014)
Covington County Bank v. Magee
177 So. 3d 826 (Mississippi Supreme Court, 2015)

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