Richard Wilbourn v. Victoria Wilbourn

CourtMississippi Supreme Court
DecidedFebruary 4, 2021
Docket2019-IA-00954-SCT
StatusPublished

This text of Richard Wilbourn v. Victoria Wilbourn (Richard Wilbourn v. Victoria Wilbourn) 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.

Bluebook
Richard Wilbourn v. Victoria Wilbourn, (Mich. 2021).

Opinion

IN THE SUPREME COURT OF MISSISSIPPI

NO. 2019-IA-00954-SCT

RICHARD WILBOURN

v.

VICTORIA WILBOURN

DATE OF JUDGMENT: 05/21/2019 TRIAL JUDGE: HON. DEWEY KEY ARTHUR TRIAL COURT ATTORNEYS: CYNTHIA H. SPEETJENS CORY T. WILSON MICHAEL R. KELLY ROBERT S. ADDISON W. TERRELL STUBBS DALE DANKS, JR. COURT FROM WHICH APPEALED: MADISON COUNTY CIRCUIT COURT ATTORNEYS FOR APPELLANT: C. MAISON HEIDELBERG CYNTHIA H. SPEETJENS ATTORNEYS FOR APPELLEE: ROBERT S. ADDISON MATTHEW THOMPSON NATURE OF THE CASE: CIVIL - OTHER DISPOSITION: AFFIRMED AND REMANDED - 02/04/2021 MOTION FOR REHEARING FILED: MANDATE ISSUED:

BEFORE RANDOLPH, C.J., COLEMAN AND CHAMBERLIN, JJ.

COLEMAN, JUSTICE, FOR THE COURT:

¶1. The present interlocutory appeal stems from a trial judge granting partial summary

judgment, dismissing a claim of malicious prosecution. We affirm.

FACTUAL AND PROCEDURAL BACKGROUND ¶2. The pertinent facts and procedural history are not disputed. Richard and Victoria have

been and remain in a longstanding domestic matter. Victoria accused Richard of misconduct

towards their children, but the chancellor determined that the accusations were unfounded.

Victoria went to the Ridgeland Police Department for help and filed an eight-page report

against Richard, restating his alleged misconduct. The Ridgeland Police Department

followed protocol, investigated, and referred the case to the district attorney’s office.

¶3. Initially, the assistant district attorney, Ashley Allen, decided against pursuing

charges. But after she wrote a letter to the Ridgeland Police Department stating her intent,

Allen was contacted by Victoria. Victoria asked Allen if she would be willing to interview

the children, and Allen complied. Afterwards, Allen revised her decision and decided to

present the case against Richard to a grand jury, charging him with gratification of lust.

¶4. The grand jury returned a no bill. Notably, Richard was never charged, indicted, or

arrested in connection with the investigation, and Victoria did not swear an affidavit against

him. In the summer of 2016, Richard discovered the investigation and grand jury

presentment and responded by filing suit. Richard claimed malicious prosecution, intentional

infliction of emotional distress, and negligent infliction of emotional distress.

¶5. In response, Victoria filed a motion for summary judgment. And after a hearing, the

trial judge granted partial summary judgment, dismissing Richard’s claim of malicious

prosecution but retaining the others. Definitively, the trial judge found that “no criminal

proceedings were instituted and therefore [Richard] cannot satisfy the first element of his

claim.”

2 ¶6. Moreover, the trial judge found that “even had criminal proceedings been instituted

against [Richard], [Richard] has not shown that [Victoria] was the initiator.” We granted

Richard’s petition for interlocutory appeal to the malicious-prosecution claim. On

interlocutory appeal, Richard raises the following three issues:

(1) Whether the trial judge erred by concluding that no criminal proceedings were instituted against Richard;

(2) Whether the trial judge erred by concluding that Victoria did not instigate the proceedings against Richard; and

(3) Whether the trial judge erred by ruling on [element two of] the premature motion for summary judgment before critical fact depositions could be taken and documentary evidence from the domestic litigation could be unsealed and presented.

¶7. For the Court to address issues two and three, issue one must be true. The critical

issue, which the Court finds dispositive, is whether a criminal proceeding was initiated

against Richard.

STANDARD OF REVIEW

¶8. “The standard of review for summary judgment is de novo.” Jarrett v. Dillard, 167

So. 3d 1147, 1151 (¶ 4) (Miss. 2015) (citing Quinn v. Estate of Jones, 818 So. 2d 1148,

1150 (¶ 9) (Miss. 2002)). “A motion for summary judgment should be granted only when

there is no genuine issue of material fact and the moving party is entitled to judgment as a

matter of law.” Id. (internal quotation marks omitted) (quoting Quinn, 818 So. 2d at 1150

(¶ 9)).

DISCUSSION

¶9. In his malicious-prosecution claim, Richard was required to prove six elements:

3 (1) the institution or continuation of original judicial proceedings, either criminal or civil;

(2) by, or at the insistence of the defendant;

(3) the termination of such proceeding in plaintiff’s favor;

(4) malice in instituting the proceedings;

(5) want of probable cause for the proceedings; and

(6) the suffering of damages as a result of the action or prosecution complained of.

Bearden v. BellSouth Telecomms., Inc., 29 So. 3d 761, 764 (¶ 8) (Miss. 2010) (quoting Van

v. Grand Casinos of Miss., Inc., 724 So. 2d 889, 891 (¶ 8) (Miss. 1998)).

¶10. On appeal, Richard claims the trial judge erred by finding that no criminal proceedings

were instituted against him. And to bolster his claim, Richard asserts that “Mississippi courts

have never ruled that a warrant, an indictment, or affidavit is a prerequisite to meet element

one’s ‘proceeding’ requirement.” Richard further argues that the trial judge’s “heightened

standard” for criminal proceeding restricts the proper analytical framework provided by

caselaw.

¶11. Richard refers to the trial judge’s use of “prosecution” from Mississippi Code Section

99-1-7 (Rev. 2020) to define a criminal proceeding. Section 99-1-7 states that “[a]

prosecution may be commenced . . . by the issuance of a warrant, or by binding over or

recognizing the offender to compel his appearance to answer the offense, as well as by

indictment or affidavit.” Miss. Code Ann. § 99-1-7 (Rev. 2020).

4 ¶12. Richard argues that the use of the above-defined term in a malicious-prosecution

claim is restrictive, narrow, and against precedent. But while there may be different

resources available to define a criminal proceeding, the trial judge did not err or “improperly

restrict” the proper analytical framework. Richard asserts that Royal Oil Co. v. Wells, 500

So. 2d 439, 443 (Miss. 1986), supports the claim that an affidavit is not mandatory and that

“the case facts here are no different than in Royal Oil where the proceeding was initiated by

signing an affidavit.”

¶13. But in Royal Oil, the focal point was probable cause and whether the actor that

initiated the criminal proceedings was an agent of the corporation. Id. at 445-48. There, the

defendant “initiated a criminal charge of embezzlement against [the plaintiff] by executing

and filing an affidavit charging [the plaintiff] with the embezzlement . . . .” Id. at 441.

Notably, a judge issued a warrant for the plaintiff’s arrest, which “was done before [the

plaintiff] was given an opportunity to explain her side of the story.” Id.

¶14. While the trial judge used a statutory definition to define the initiation of a criminal

proceeding, such finding was supported by caselaw: “In practical effect, criminal proceedings

are instituted when a person is formally arrested and charged with an offense.” City of

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Related

Owens v. Kroger Co.
430 So. 2d 843 (Mississippi Supreme Court, 1983)
Benjamin v. Hooper Electronic Supply Co.
568 So. 2d 1182 (Mississippi Supreme Court, 1990)
Bearden v. Bellsouth Telecommunications, Inc.
29 So. 3d 761 (Mississippi Supreme Court, 2010)
Quinn v. Estate of Jones
818 So. 2d 1148 (Mississippi Supreme Court, 2002)
City of Mound Bayou v. Johnson
562 So. 2d 1212 (Mississippi Supreme Court, 1990)
Royal Oil Co., Inc. v. Wells
500 So. 2d 439 (Mississippi Supreme Court, 1986)
Winters v. Griffis
101 So. 2d 346 (Mississippi Supreme Court, 1958)
Van v. Grand Casinos of Miss., Inc.
724 So. 2d 889 (Mississippi Supreme Court, 1998)
Larry Jarrett v. Robert Houston Dillard
167 So. 3d 1147 (Mississippi Supreme Court, 2015)
William Scott Ashwell v. State of Mississippi
226 So. 3d 69 (Mississippi Supreme Court, 2017)

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Bluebook (online)
Richard Wilbourn v. Victoria Wilbourn, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richard-wilbourn-v-victoria-wilbourn-miss-2021.