Connie Hawkins v. Heck Yea Quarter Horses, LLC, 2016-CA-00215-COA

George Hawkins, a temporary employee at Heck Yea Quarter Horses, became ill (heat stroke/stroke symptoms) on his first day while working on the defendant’s farm.
Co-worker Horn placed George in shade, gave him a cold drink, asked twice whether he wanted an ambulance or a ride home, and George declined both offers.
George left the premises and was later found at home in distress; Hawkins called an ambulance about two hours after he left the farm; George later died.
Hawkins sued for wrongful death, alleging Heck Yea breached its duty to render aid (or to summon aid) to an invitee; she relied partly on an alleged co-worker statement that George was incoherent.
The trial court granted summary judgment for Heck Yea, finding the good‑samaritan statute applied; the Court of Appeals affirmed, concluding either the statute or negligence principles did not produce a genuine issue of material fact that defendant’s conduct proximately caused death.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the good‑samaritan statute governs the duty owed when a landowner/possessor renders aid to an invitee	Hawkins: general negligence/premises‑liability applies because George was a business invitee and Heck Yea owed a duty to summon aid despite his refusal	Heck Yea: good‑samaritan protections apply to those who render emergency care in good faith; they offered aid and George refused	Court: The statute can coexist with negligence principles, but here no actionable breach or proximate causation was shown; summary judgment affirmed
Whether plaintiff produced admissible evidence creating a genuine issue that defendant breached duty or caused death	Hawkins: testimony (via deposition/affidavits) that George was incoherent and should have had ambulance called creates a dispute of material fact	Heck Yea: contrary testimony from Horn and hearsay issues make Hawkins’s evidence inadmissible; they satisfied their duty by offering aid and asking twice about emergency services	Court: Hawkins’s contrary evidence was inadmissible double hearsay and insufficient; admissible evidence shows reasonable aid was rendered and George declined assistance; no genuine issue of causation

Stuckey v. The Provident Bank, 912 So. 2d 859 (summary judgment burden and standard)
Ladner v. Holleman, 90 So. 3d 655 (good‑samaritan statute can coexist with negligence principles when aid is voluntarily rendered)
Hudson v. Courtesy Motors Inc., 794 So. 2d 999 (definition of invitee and duty to business invitees)
Spotlite Skating Rink Inc. v. Barnes, 988 So. 2d 364 (landowner duty to render reasonable first aid to invitees)
Estate of White ex rel. White v. Rainbow Casino‑Vicksburg P’ship, 910 So. 2d 713 (duty to render aid abates when a competent patron refuses medical aid)
O’Gwin v. Isle of Capri Natchez Inc., 139 So. 3d 783 (elements of negligence and duty framework)