Cooper v. Estate of Gatwood, 119 So. 3d 1031

1996 Lamar County divorce decree required Gatwood to pay child support, life insurance, medical insurance, and medical expenses for his minor children.
In 2009, the chancery court awarded Cooper $68,671.27 for overdue insurance and medical costs, to be paid in $200 monthly installments with no interest.
On December 1, 2010, Parsons filed a garnishment suggestion in circuit court against Lamar Auto Salvage, claiming Gatwood owed the $68,671.27 plus 8% interest, but failed to disclose the installment order and Gatwood’s current payment status.
The circuit court defaulted Lamar Auto Salvage, then granted a settlement agreement directing Lamar to pay Cooper, after which Gatwood’s garnishment actions continued and sanctions were sought.
Gatwood died on June 29, 2012; this appeal concerns sanctions and related rulings, with issues about mootness and party joinder.
The Lamar County Circuit Court sanctioned Parsons and Cooper for misrepresentations, voided the garnishment against Lamar Auto, and the estate challenges those rulings on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sanctions proper under Rule 11 and Litigation Accountability Act	Cooper/Parsons acted in good faith; sanctions unjust	Court should uphold sanctions for misrepresentation	Sanctions upheld; misrepresentations justified sanctions
Gatwood’s joinder: timeliness and standing	Gatwood timely joined; had standing	Gatwood was untimely and lacked standing	Timely joinder allowed; Gatwood had standing under Rule 19
Whether insurance/medical expenses vest as regular child support	Expenses vest only as per chancellor’s installment order	Expenses constitute regular child support vesting immediately	Not plain error; installment order valid; misrepresentation remediable by appeal
Mootness due to Gatwood’s death	Issues moot; relief cannot be granted	Death does not moot issues already in appeal; some remedies remain	Not properly before court; mootness not dispositive

In re Spencer, 985 So.2d 330 (Miss. 2008) (defines frivolous under Rule 11 and LAA)
In re Estate of Ladner, 909 So.2d 1051 (Miss. 2004) (sanctions upheld for misrepresentation by counsel)
First Mississippi National Bank v. KLH Industries, Inc., 457 So.2d 1333 (Miss. 1984) (garnishment proceedings are civil actions governed by MRCP)