Yazoo City, Mississippi v. Kenneth Hampton and Victor Young

CourtMississippi Supreme Court
DecidedMay 30, 2024
Docket2022-IA-01284-SCT
StatusPublished

This text of Yazoo City, Mississippi v. Kenneth Hampton and Victor Young (Yazoo City, Mississippi v. Kenneth Hampton and Victor Young) 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
Yazoo City, Mississippi v. Kenneth Hampton and Victor Young, (Mich. 2024).

Opinion

IN THE SUPREME COURT OF MISSISSIPPI

NO. 2022-IA-01284-SCT

YAZOO CITY, MISSISSIPPI

v.

KENNETH HAMPTON AND VICTOR YOUNG

DATE OF JUDGMENT: 12/05/2022 TRIAL JUDGE: HON. JANNIE M. LEWIS-BLACKMON TRIAL COURT ATTORNEYS: THOMAS RAY JULIAN STEVEN JAMES GRIFFIN RONALD EARL STUTZMAN, JR. COURT FROM WHICH APPEALED: YAZOO COUNTY CIRCUIT COURT ATTORNEY FOR APPELLANT: THOMAS RAY JULIAN ATTORNEY FOR APPELLEES: RONALD EARL STUTZMAN, JR. NATURE OF THE CASE: CIVIL - PROPERTY DAMAGE DISPOSITION: REVERSED AND RENDERED - 05/30/2024 MOTION FOR REHEARING FILED:

BEFORE KITCHENS, P.J., BEAM AND ISHEE, JJ.

ISHEE, JUSTICE, FOR THE COURT:

¶1. A fire that burned Kenneth Hampton’s and Victor Young’s properties in Yazoo City,

Mississippi, presents this Court with two questions in this interlocutory appeal. First, is

Yazoo City immune from liability under the Mississippi Tort Claims Act (MTCA) for

property damage caused by its fire department’s failure to effectively fight the fire? Second,

if the city is immune, does that immunity extend to personal injury claims arising from

injuries suffered after the fire due to alleged stress caused by the property damage?

¶2. The Yazoo County Circuit Court ruled that neither question was answerable without

additional discovery and therefore denied Yazoo City’s motion for summary judgment. Upon review, however, we find that Yazoo City is immune from both property damage and

personal injury liability under these facts. We therefore reverse the circuit court’s denial of

the motion for summary judgment and render judgment in favor of Yazoo City.

FACTS

¶3. On November 18, 2020, a fire broke out at Young’s property in Yazoo City. The

Yazoo City Fire Department responded, but extinguishing the fire proved difficult for two

reasons: (1) a lack of tank water in the fire department’s truck and (2) an inability to connect

to a nearby fire hydrant.

¶4. The fire spread, eventually reaching Hampton’s property. Only after the fire

department enlisted a nearby retired fireman to help connect to the hydrant was the fire

extinguished. And by that time, Young’s property had become a total loss. Hampton’s

property had also been significantly damaged by both fire and smoke.

¶5. The record reveals that neither Young nor any person other than fire department

personnel was on Young’s property during the fire. Hampton was present at his property,

but he was not trapped in the fire or subjected to any fire department action. He instead

looked on and eventually “pour[ed] water on his vehicles . . . trying to preserve [them] from

getting engulfed in flames . . . .”

¶6. Despite his preservation efforts, Hampton was not injured in the fire. Three days1

after the fire was extinguished, however, he “suffered a cardiac event and subsequent stroke”

1 In the original complaint, Hampton claimed he suffered his injuries three days after the fire. On appeal, however, he claims that the onset of his symptoms actually came one day after the fire and that the three day figure was based on the time of the University of Mississippi Medical Center’s diagnosis.

2 but survived following treatment at the University of Mississippi Medical Center.

¶7. On February 3, 2022, Hampton and Young brought suit against Yazoo City. They

alleged the city (1) acted negligently and demonstrated reckless disregard by failing to

provide the requisite knowledge and equipment to fight fires, (2) failed to properly train and

supervise its firefighters, and (3) failed to adequately maintain its fire hydrant system.

Further, they sought a judgment against Yazoo City “for their property damage, lost rents,

medical expenses, mental and emotional distress, and lost wages.”

¶8. Yazoo City filed its answer and defenses on March 30, 2022. In doing so, it invoked

the MTCA as a defense to any liability claimed in Hampton and Young’s complaint. The

next day, Yazoo City filed a motion to (1) stay or limit discovery and (2) preserve its

defenses and immunities if it participated in discovery. In the motion, the city requested that

discovery be limited to matters relevant to determining immunity, and it emphasized the

importance of quickly resolving the immunity issue prior to proceeding with litigation.

¶9. Before the circuit judge ruled on the motion, however, Yazoo City filed a motion for

summary judgment on September 23, 2022. The city argued that because Hampton and

Young did not allege the city “acted with reckless disregard for the safety and well-being of

any person,” it was entitled to immunity under Mississippi Code Section 11-46-9(1)(c).

¶10. Hampton and Young responded to the motion for summary judgment on September

30, 2022. They attached the affidavit of their counsel, Ronald E. Stutzman, Jr., for the

purpose of requesting additional time to conduct discovery under Mississippi Rule of Civil

Procedure 56(f). As to what additional discovery would yield, the affidavit contained only

3 the following: “[Hampton and Young] cannot defend against Yazoo City’s Motion for

Summary Judgment without the benefit of discovery.”

¶11. Yazoo City then filed a rebuttal in support of its motion for summary judgment on

October 7, 2022. It (1) reiterated the arguments set forth in its motion for summary judgment

and (2) alleged Hampton and Young failed to meet the requirements under Rule 56(f) to

qualify for additional discovery.

¶12. A hearing on Yazoo City’s motion for summary judgment was held on November 29,

2022, in which both parties presented their arguments. At the conclusion of the hearing, the

circuit court determined that there remained “issues of material facts . . . .” And on

November 29, 2022, the circuit court entered an order (1) denying Yazoo City’s motion for

summary judgment and (2) allowing the parties to conduct discovery “without Yazoo City

waiving any immunities under the [MTCA].” In response, Yazoo City filed a petition for

interlocutory appeal on the two immunity questions, which this Court granted on March 10,

2023.

STANDARD OF REVIEW

¶13. “The Court reviews a trial court’s grant or denial of summary judgment de novo.”

Collins v. City of Newton, 240 So. 3d 1211, 1216 (Miss. 2018) (citing Crosthwait v. S.

Health Corp. of Houston, Inc., 94 So. 3d 1070, 1073 (Miss. 2012)). “Summary judgment

is appropriate when ‘the pleadings, depositions, answers to interrogatories and admissions

on file, together with the affidavits, if any, show that there is no genuine issue of material

fact[.]’” Id. (alteration in original) (quoting M.R.C.P. 56(c)). “The evidence must be viewed

4 in the light most favorable to the opposing party.” Id. (citing Duckworth v. Warren, 10 So.

3d 433, 436-37 (Miss. 2009)).

DISCUSSION

1. Immunity from Property Damage Liability

¶14. On appeal, Yazoo City claims that “[b]ecause [it] is immune from liability for

allegedly acting in reckless disregard of [Hampton’s and Young’s] property, there can be no

genuine issue of material fact on that issue, and [its] Motion for Summary Judgment should

have been granted.” Regarding immunity, Mississippi Code Section 11-46-9(1)(c) provides:

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Related

Duckworth v. Warren
10 So. 3d 433 (Mississippi Supreme Court, 2009)
William Donald Collins, Sr. v. City of Newton
240 So. 3d 1211 (Mississippi Supreme Court, 2018)
Crosthwait v. Southern Health Corp. of Houston, Inc.
94 So. 3d 1070 (Mississippi Supreme Court, 2012)

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Yazoo City, Mississippi v. Kenneth Hampton and Victor Young, Counsel Stack Legal Research, https://law.counselstack.com/opinion/yazoo-city-mississippi-v-kenneth-hampton-and-victor-young-miss-2024.