Board of Supervisors of Jackson County, Mississippi v. Qualite Sports Lighting, LLC, 337 So.3d 1040

Jackson County solicited bids for athletic-field lighting (HID base bid; LED alternate); only Musco and Qualite prequalified.
Bids submitted via electronic reverse auction; Qualite’s LED price was slightly lower but had a longer delivery time; project engineer reported Musco was faster and more responsive on warranty issues.
Board of Supervisors awarded the LED contract to Musco as the "lowest and best bidder."
Qualite timely appealed under the 2018-amended Miss. Code § 11-51-75, designated additional documents it said were not before the board, issued subpoenas, and sought a discovery period.
The circuit court denied Qualite’s request for discovery but ordered the record supplemented with Qualite’s designated materials and denied the board’s motion to quash subpoenas; the board obtained an interlocutory appeal to the Mississippi Supreme Court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 2018 amendment to §11-51-75 permits expanding the appellate record beyond materials actually presented to the board (including discovery/new evidence).	Qualite: the amended statutory designation scheme allows inclusion of additional materials and limited discovery to show irregularities in the board’s decision.	Board: appeal is appellate in nature and limited to the record of proceedings before the board; new evidence/discovery is not permitted.	Held: Appeal is limited to the record made before the board; new evidence/discovery not allowed. Circuit court’s order permitting expansion beyond that record is reversed.
Whether the circuit court properly ordered supplementation and refused to quash subpoenas (and how disputes over the record should be resolved).	Qualite: supplementation and subpoenas were necessary to produce a complete record for review.	Board: supplementation and subpoenas improperly seek materials outside the board’s record; disputes should be resolved consistent with appellate procedure.	Held: Circuit court may determine what must be included to make the record fair, accurate, and complete, but must do so under procedures informed by MRAP 10; supplementation limited to materials necessary to reflect what transpired before the board.

Am. Tower Asset Sub, LLC v. Marshall Cnty., 324 So. 3d 300 (Miss. 2021) (interpreting aspects of the 2018 amendment to §11-51-75)
City of Jackson v. Allen, 242 So. 3d 8 (Miss. 2018) (discussing the bill-of-exceptions procedure and appellate record preservation)
Falco Lime, Inc. v. Mayor & Aldermen of Vicksburg, 836 So. 2d 711 (Miss. 2002) (circuit court reviewing a board’s decision sits only as an appellate court and generally may consider no evidence outside the record)
In re Validation of Tax Anticipation Note v. Humphreys Cnty. Bd. of Supervisors, 187 So. 3d 1025 (Miss. 2016) (Rule 10(e) is for correcting the appellate record, not admitting new evidence)
Corrothers v. State, 148 So. 3d 278 (Miss. 2014) (explaining limits of Rule 10(e) and appellate record correction)
Lawson v. Honeywell Int’l, Inc., 75 So. 3d 1024 (Miss. Ct. App. 2011) (statutory interpretation principles: courts will not presume the legislature intended to reverse established rules absent clear language)