Anita White v. Charles Tommy White, 152 So. 3d 314

Anita White sued to set aside quit-claim deeds transferring partnership property acquired by Tommy White via power of attorney.
Conservatorship for Bill White was opened in 2009, with Tommy as proposed conservator and a third party ultimately appointed.
Conservator discharged after Bill's death in June 2009, distributing assets to Bill's estate; order did not address Anita's challenge to the deeds.
Anita later filed suit in 2010 to set aside the conveyances, arguing transfers were not in Bill’s best interests.
Trial court & Court of Appeals held Anita's action barred by res judicata based on the conservatorship proceedings.
Mississippi Supreme Court reversed, holding there was no final merits judgment in the prior proceeding and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does res judicata bar Anita’s suit?	White argues prior order lacked final merits judgment.	White contends four identities of res judicata were met and bar applies.	No final merits judgment; res judicata does not bar.
Was the conservatorship discharge a final judgment on the merits?	Anita contends discharge did not resolve the contested issues on their merits.	Tommy contends the discharge was a merits-based final disposition.	Discharge was not a final judgment on the merits.

EMC Mortgage Corp. v. Carmichael, 17 So. 3d 1087 (Miss. 2009) (prior judgment must be on the merits for res judicata)
Anderson v. LaVere, 895 So. 2d 828 (Miss. 2004) (four identities framework for res judicata)
Hill v. Carroll Cnty., 17 So. 3d 1081 (Miss. 2009) (four identities defined for res judicata)
Harrison v. Chandler-Sampson Ins., Inc., 891 So. 2d 224 (Miss. 2005) (identities analysis for res judicata)
Costello v. United States, 365 U.S. 265 (1961) (merits vs. procedural grounds in judgments)