Jack Parsons and Parsons Law Firm v. Vernon Walters and Donyell Walters, 297 So.3d 250

Vernon Walters was injured in a 2006 work-related train collision; he received $195,471.66 in workers’ compensation and (with his wife Donyell) sued Kansas City Southern Railway Co. (KCSR) as a third-party defendant.
The federal court dismissed the KCSR suit with prejudice in 2010 for Vernon’s false deposition testimony and the Parsons attorney’s discovery failures; Tadd Parsons did not tell the Walterses the case was dismissed.
Over two years later Tadd fabricated a $104,000 settlement offer from KCSR, advised the Walterses to accept, and they did; the falsity was later discovered and the Walterses sued Tadd, Jack Parsons, and the Parsons Law Firm for fraud and intentional infliction of emotional distress (IIED).
The trial court granted partial summary judgment for the Walterses on liability for fraud and IIED as to Tadd and the firm (Jack potentially vicariously liable); the damages phase went to a jury limited to damages.
The jury awarded $2,850,002 in compensatory damages; the trial judge found the award excessive, entered a remittitur to $1,134,666.67, and Parsons appealed (Walters cross-appealed to reinstate the jury verdict).
The Mississippi Supreme Court affirmed the exclusion of evidence about the KCSR proceedings, concluded the record did not support the remitted damages award, reversed the remitted judgment, and remanded for a new trial on damages; the Walterses’ cross-appeal was dismissed as moot.

Issue	Plaintiff's Argument (Walters)	Defendant's Argument (Parsons)	Held
Whether the trial court erred by granting the motion in limine excluding Vernon’s deposition and other KCSR-case evidence	Exclusion proper because evidence was irrelevant to damages for fraud and IIED and prejudicial	Evidence was probative of the underlying claim’s value and thus relevant to quantify damages and mitigation	Motion in limine properly granted; KCSR evidence was irrelevant to the damages limited to fraud/IIED from the fabricated settlement
Whether the jury’s damages award (and the trial court’s remitted award) were supported by substantial evidence	Testimony and circumstances (fabrication, deceit, upset) justified the jury award	Award was speculative, punitive in nature, and unsupported by proof of compensable emotional distress or measurable reliance losses	The record lacked sufficient evidence to support the remitted compensatory award; damages were excessive — reversed and remanded for new trial on damages
Whether the jury verdict should be reinstated on cross-appeal after remittitur	Jury verdict should be reinstated	Trial court’s remittitur appropriate given pleading limits and weight-of-evidence concerns	Cross-appeal dismissed as moot because remitted award was reversed and case remanded for new damages trial

Ill. Cent. R.R. Co. v. Brent, 133 So. 3d 760 (Miss. 2013) (abuse-of-discretion standard for evidentiary rulings)
APAC–Miss., Inc. v. Goodman, 803 So. 2d 1177 (Miss. 2002) (Rule 401 favors admission if evidence has probative value)
U.S. Fid. & Guar. Co. of Miss. v. Martin, 998 So. 2d 956 (Miss. 2008) (abuse-of-discretion standard for remittitur review)
Community Bank, Ellisville, Miss. v. Courtney, 884 So. 2d 767 (Miss. 2004) (courts will not disturb jury award absent insufficient proof)
Cook v. Children’s Med. Group, P.A., 756 So. 2d 734 (Miss. 1999) (fraud permits recovery for reliance damages and emotional distress)
Gamble ex rel. Gamble v. Dollar Gen. Corp., 852 So. 2d 5 (Miss. 2003) (examples of compensable emotional-distress evidence without expert testimony)
Whitten v. Cox, 799 So. 2d 1 (Miss. 2000) (standards and examples for emotional-distress awards)
Morrison v. Means, 680 So. 2d 803 (Miss. 1996) (insufficient proof of injury defeats large mental-anguish recovery)
Stewart v. Gulf Guaranty Life Ins. Co., 846 So. 2d 192 (Miss. 2002) (medical testimony and corroboration can sustain large emotional-distress awards)
Leaf River Forest Prods., Inc. v. Ferguson, 662 So. 2d 648 (Miss. 1995) (defendant’s mental state considerations for emotional-distress damages)