Housing Authority of The City of Yazoo City, Mississippi, Dana Neely, Chairman, Veronica Starling, Commissioner, Mamie J. Williams, Vice Chairman, Carolyn Johnson, Commissioner, Herbert Scott, Jr., Commissioner, In Their Official Capacity v. Alpresteon S. Billings, 404 So.3d 1148

Alpresteon Billings was selected as executive director of the Yazoo City Housing Authority in July 2018, with an expectation of a five-year contract and annual salary increases.
The board entered executive session on July 31, 2018, where minutes indicate approval of an executive director’s contract, but no contract terms were included in the minutes nor attached.
Billings assumed the role; however, changes in board membership occurred, and she was terminated in February 2019 after a few months.
Billings sued the Housing Authority for breach of contract and the commissioners for other employment-related claims.
The trial court granted summary judgment to the commissioners, but allowed the breach-of-contract claim against the Housing Authority to proceed, finding issues of fact remained.
On interlocutory appeal, the Supreme Court reviewed whether any enforceable employment contract existed based on the board’s minutes.

Issue	Billings' Argument	Housing Authority's Argument	Held
Whether an enforceable employment contract existed between Billings and the Housing Authority	The board approved a five-year contract; she reasonably relied on this, as documented by a letter and affidavits	The board’s minutes did not set out contract terms or even mention Billings; any contract must have its basic terms in the minutes to be enforceable	No enforceable contract existed; the claim fails as a matter of law
Whether employment contracts are subject to the public board minutes requirement	The requirement does not apply to employment contracts	The minutes rule applies to all contracts, including employment	The minutes rule applies to employment contracts
Whether extrinsic evidence can supply missing contract terms for public board employment	Reliance on officer letter and commissioners’ affidavits is sufficient	Only terms in the board’s minutes are relevant; extrinsic evidence cannot be used	Only board minutes govern; extrinsic evidence is not competent
Whether the summary judgment denial was proper on the breach-of-contract claim	Genuine issues of fact existed supporting denial of summary judgment	No genuine issue because minutes lacked contract terms, so claim fails as matter of law	Reversed; summary judgment granted for Housing Authority

Thompson v. Jones Cnty. Cmty. Hosp., 352 So. 2d 795 (Miss. 1977) (public boards can only bind themselves by what appears in their official minutes)
KPMG, LLP v. Singing River Health System, 283 So. 3d 662 (Miss. 2019) (reaffirming public board contracts must be evidenced in board minutes)
Cheatham v. Smith, 92 So. 2d 203 (Miss. 1957) (actions of public boards evidenced solely by entries on board minutes)
Bd. of Supervisors of Adams Cnty. v. Giles, 68 So. 2d 483 (Miss. 1953) (each contracting party must ensure a contract is properly recorded in the public board’s minutes)