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Chaffee v. Jackson Public School District

Supreme Court of Mississippi

May 16, 2019

SONYA CHAFFEE ON BEHALF OF FREDRICK C. LATHAM, A MINOR
v.
JACKSON PUBLIC SCHOOL DISTRICT, LONNIE J. EDWARDS AND JACKSON PUBLIC SCHOOL BOARD OF TRUSTEES

          DATE OF JUDGMENT: 11/29/2017

          HINDS COUNTY CIRCUIT COURT HON. JEFF WEILL, SR. JUDGE

          JERALD DEWAYNE CRAWFORD ATTORNEY FOR APPELLANT

          STEVEN LLOYD LACEY ATTORNEY FOR APPELLEES

          BEFORE KING, P.J., COLEMAN AND BEAM, JJ.

          BEAM, JUSTICE

         ¶1. Sonya Chaffee, on behalf of her minor child, Fredrick Latham, Jr., sued the Jackson Public School District; Lonnie J. Edwards, the School District superintendent in his official capacity; and Jackson Public Schools Board of Trustees (collectively, "the School District") on November 16, 2010, alleging negligence and res ipsa loquitur. The School District answered on March 3, 2011, raising as an affirmative defense sovereign immunity under the Mississippi Tort Claims Act ("MTCA"). After engaging in discovery, the School District filed its motion for summary judgment on March 1, 2016, which the Hinds County Circuit Court granted.

         ¶2. Aggrieved, Chaffee appeals. Finding no reversible error, this Court affirms.

         FACTS AND PROCEDURAL HISTORY

         ¶3. On February 8, 2010, Fredrick was a student in Tracy Scott's first grade class at Woodville Heights Elementary School. While Scott was standing at the front of the classroom readying the students for lunch, Fredrick and another boy got out of line and ran to the back of the classroom to use the single restroom. Bernice Anderson, Scott's teaching assistant, was present at her desk in the back of the classroom nearer the restroom.

         ¶4. Fredrick was injured when his hand slipped off the door and his finger got caught in the crack of the door as the other boy was closing it. After hearing a student scream that Fredrick had smashed his finger, Scott went to the back of the classroom, wrapped Fredrick's finger in papers towels, and took him to the principal's office. Fredrick's mother was called, and he was taken by ambulance to the University of Mississippi Medical Center. Dr. Michael Angel performed surgery to reattach Fredrick's fingertip using a skin graft.

         ¶5. On November 16, 2010, Chaffee filed suit in the Hinds County Circuit Court asserting claims of negligence and res ipsa loquitur. The School District filed its answer and defenses on March 3, 2011. The parties engaged in discovery and agreed to a scheduling order, which was entered in October 2015. On March 1, 2016, the School District filed its motion for summary judgment. Chaffee filed her response, and the School District filed its rebuttal.

         ¶6. On September 25, 2017, a hearing was held on the summary-judgment motion. The trial court ruled,

In this instance after review of the pleadings, I don't believe and in my opinion there was a genuine issue of material fact as to whether the children were supervised and I believe that's the standard. The parties agree there were two adults in a supervisory capacity in the room which I believe is what the law as mandate and school policy requires. Some kids violated that. I'm not sure what the school district or the teacher or the ...

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