Natchez-Adams School District v. Tina Bruce

CourtCourt of Appeals of Mississippi
DecidedSeptember 9, 2014
Docket2012-CA-00147-COA
StatusPublished

This text of Natchez-Adams School District v. Tina Bruce (Natchez-Adams School District v. Tina Bruce) 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
Natchez-Adams School District v. Tina Bruce, (Mich. Ct. App. 2014).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2012-CA-00147-COA

NATCHEZ-ADAMS SCHOOL DISTRICT APPELLANT

v.

TINA BRUCE APPELLEE

DATE OF JUDGMENT: 10/20/2011 TRIAL JUDGE: HON. LILLIE BLACKMON SANDERS COURT FROM WHICH APPEALED: ADAMS COUNTY CIRCUIT COURT ATTORNEYS FOR APPELLANT: ROBERT O. ALLEN WILLIAM ROBERT ALLEN JOHN CHADWICK WILLIAMS ATTORNEYS FOR APPELLEE: PHILIP ELMER CARBY EDGAR HYDE CARBY NATURE OF THE CASE: CIVIL - PERSONAL INJURY TRIAL COURT DISPOSITION: FOUND APPELLANT LIABLE FOR APPELLEE’S INJURIES AND AWARDED APPELLEE $488,000 IN DAMAGES DISPOSITION: AFFIRMED - 09/09/2014 MOTION FOR REHEARING FILED: MANDATE ISSUED:

EN BANC.

ROBERTS, J., FOR THE COURT:

¶1. Tina Bruce sued the Natchez-Adams School District (NASD) after she tripped over

a section of conduit that protruded from the surface of a driveway in front of NASD’s

administrative building. After a bench trial, the Adams County Circuit Court awarded Bruce

$488,000 in damages. NASD appeals. According to NASD, it is immune to Bruce’s claim

under either the discretionary-function exemption or the dangerous-condition exemption of

the Mississippi Tort Claims Act (MTCA). Finding no error, we affirm. FACTS AND PROCEDURAL HISTORY

¶2. In July 2008, Bruce visited NASD’s administrative building in Natchez, Mississippi,

to deliver a job application. As Bruce was walking across the concrete driveway in front of

the administrative building, she tripped over a section of conduit that protruded more than

an inch above the driveway’s surface. At trial, Bruce testified that she had two bulging discs

in her back and leg pain as a result of her fall. She attempted to alleviate her injuries through

physical therapy and pain management. When those remedies produced unsatisfactory

results, she underwent spinal surgery. Her necessary medical expenses exceeded $143,000.

The circuit court noted that Bruce will have to walk with a cane for the rest of her life. The

circuit court further noted that Bruce was permanently impaired and has functional

limitations and “work restrictions.” Additionally the circuit court stated that Bruce “has

endured pain and suffering and will continue to do so for the rest of her life” and “[h]er

family life is altered.”

¶3. The protruding conduit that caused Bruce’s fall contained the power supply to a lit

sign and architectural lighting in front of the administrative building. NASD had intended

for the conduit to be recessed into an expansion joint in the driveway. But due to the length

of the conduit, the pitch of the surface of the driveway, and continued vehicular traffic, the

conduit tended to rise above the driveway.

¶4. Before Bruce tripped over the conduit, NASD had attempted to prevent the conduit

from protruding above the surface of the driveway. Dr. Wayne Barnett, the former director

of operations for NASD, testified that the conduit was a “slip, trip, and fall hazard,” so he

“got the ball rolling to get it fixed.” Willie Ellis, an electrician for NASD, attempted to

2 prevent the conduit from protruding above the surface of the driveway by drilling a “spike”

into the driveway and then bending it over the conduit to hold it in place. Dr. Barnett

inspected Ellis’s work and became satisfied that the conduit was no longer a trip hazard.

However, Dr. Barnett also testified that he did not check on the conduit after his initial

inspection to determine whether the “spike” was still preventing the conduit from protruding

above the surface of the driveway. Over time, the conduit became dislodged from the

“spike” and again protruded approximately two inches above the surface of the driveway.

¶5. NASD employees Isaac King and Jimmy Wilson testified that the conduit made a

rattling noise when a car drove over it. They also noticed that the conduit was protruding

above the surface of the driveway. They told NASD maintenance supervisor Demestra

Winding about the protruding conduit at least once before Bruce fell.

¶6. As previously mentioned, NASD argued that it was entitled to immunity under the

discretionary-function-exemption and the dangerous-condition-exemption provisions of the

MTCA. The circuit court disagreed and awarded Bruce $488,000 in damages. NASD

appeals.

ANALYSIS

I. DISCRETIONARY-FUNCTION EXEMPTION

¶7. NASD argues that it was entitled to immunity under the discretionary-function

exemption of the MTCA. In the context of a lawsuit alleging that a governmental entity is

liable for negligence, the MTCA is a plaintiff’s exclusive remedy. S. Cent. Reg’l Med. Ctr.

v. Guffy, 930 So. 2d 1252, 1255 (¶7) (Miss. 2006). “Questions concerning the application

of the MTCA are reviewed de novo.” Miss. Dep’t of Pub. Safety v. Durn, 861 So. 2d 990,

3 994 (¶7) (Miss. 2003). “Immunity is a question of law.” Id. However, we will not disturb

the circuit court’s factual findings if there is substantial credible evidence to support them.

City of Natchez v. Jackson, 941 So. 2d 865, 869 (¶9) (Miss. Ct. App. 2006).

¶8. The discretionary-function exemption is set forth in Mississippi Code Annotated

section 11-46-9(1)(d) (Rev. 2012), which provides:

A governmental entity and its employees acting within the course and scope of their employment or duties shall not be liable for any claim . . . [b]ased upon the exercise or performance or the failure to exercise or perform a discretionary function or duty on the part of a governmental entity or employee thereof, whether or not the discretion be abused[.]

“A duty is discretionary when it is not imposed by law and depends upon the judgment or

choice of the government entity or its employee.” Miss. Transp. Comm’n v. Montgomery,

80 So. 3d 789, 795 (¶19) (Miss. 2012). “A duty is ministerial if it is positively imposed by

law and required to be performed at a specific time and place, removing an officer’s or

entity’s choice or judgment.” Id.

¶9. In a recent opinion, the Mississippi Supreme Court significantly changed the manner

in which we are to analyze questions regarding the discretionary-function exemption to the

MTCA. Overruling nine prior decisions, the supreme court held that “[i]t is the function of

a governmental entity – not the acts performed in order to achieve that function – to which

immunity does or does not ascribe under the MTCA.” Little v. Miss. Dep’t of Transp., 129

So. 3d 132, 138 (¶10) (Miss. 2013). In other words, we are required to “look at the function

performed – not the acts that are committed in furtherance of that function – to determine

whether immunity exists.” Id. at 136 (¶8). In Little, the function at issue was the Mississippi

Department of Transportation’s statutory obligation to maintain and repair state highways.

4 Id. at 134 (¶2). The applicable statute in Little provides:

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Related

Mississippi Dept. of Public Safety v. Durn
861 So. 2d 990 (Mississippi Supreme Court, 2003)
City of Natchez v. Jackson
941 So. 2d 865 (Court of Appeals of Mississippi, 2006)
Mississippi Dept. of Mental Health v. Hall
936 So. 2d 917 (Mississippi Supreme Court, 2006)
Mississippi Dept. of Transp. v. Trosclair
851 So. 2d 408 (Court of Appeals of Mississippi, 2003)
Hayes v. University of Southern Mississippi
952 So. 2d 261 (Court of Appeals of Mississippi, 2006)
Donaldson v. Covington County
846 So. 2d 219 (Mississippi Supreme Court, 2003)
City of Newton v. Lofton
840 So. 2d 833 (Court of Appeals of Mississippi, 2003)
South Cent. Regional Med. Center v. Guffy
930 So. 2d 1252 (Mississippi Supreme Court, 2006)
Mississippi Transportation Commission v. Montgomery
80 So. 3d 789 (Mississippi Supreme Court, 2012)
Little v. Mississippi Department of Transportation
129 So. 3d 132 (Mississippi Supreme Court, 2013)

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