Annie Figures v. Jackson Housing Authority, 2015-CA-01339-COA

Annie Figures was a tenant at Golden Key Apartments, a JHA-operated housing project for disabled/elderly residents.
Figures allegedly threatened two neighbors (reportedly saying she would “blow their heads off”), violating her lease; JHA issued an eviction notice after a due-process hearing.
After Figures did not vacate, JHA obtained an eviction order in justice court and filed a civil eviction action; Figures appealed to county court, which held a de novo trial and ordered eviction and a prohibition on threatening/harassing tenants.
Figures appealed to the Hinds County Circuit Court, which affirmed the county court; Figures appealed to this Court of Appeals.
The appellate court reviewed the record and affirmed the circuit court’s judgment, finding JHA proved the lease violation and identifying no reversible error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court shifted burden of proof to Figures	Figures: court improperly shifted burden to her to prove innocence	JHA: record evidence established eviction grounds regardless of allocation	Court: shift was error but harmless because facts undisputed and JHA met its proof requirement; affirm
Whether permitting Theotis Davis to testify violated sequestration rule	Figures: Davis violated Rule 615 and his testimony should be excluded	JHA: Davis’s testimony duplicated existing record and caused no prejudice	Court: allowing Davis was not an abuse of discretion; any sequestration violation did not produce probable prejudice; affirm
Whether judge assumed adversarial role in questioning a witness	Figures: judge’s questioning of tenant Vance showed partiality and was improper	JHA: judge’s brief clarification questions were impartial and within authority	Court: questioning was impartial clarification under M.R.E. 614(b); no abuse of discretion; affirm

Norris v. Sw. Miss. Reg'l Med. Ctr., 105 So. 3d 410 (Miss. Ct. App. 2012) (substantial-evidence standard for bench-findings)
White v. State, 127 So. 3d 170 (Miss. 2013) (abuse-of-discretion review for sequestration issues)
Mitchell v. Barnes, 96 So. 3d 771 (Miss. Ct. App. 2012) (abuse-of-discretion standard for evidentiary rulings)
Clark v. State, 127 So. 3d 292 (Miss. Ct. App. 2013) (remedies for sequestration violations and prejudice requirement for exclusion)
Sheppard v. Miss. State Highway Patrol, 693 So. 2d 1326 (Miss. 1997) (misallocation of burden may be harmless when facts undisputed)
SKL Inv. Inc. v. Hardin, 170 So. 3d 588 (Miss. Ct. App. 2014) (trial judge may interrogate witnesses; reversal only if judge abandons impartiality)