Janet K. Sanford v. Walter Dudley, 196 So. 3d 1106

Janet Sanford sued neighbors Walter and Tracy Dudley alleging culvert, stone wall, and pipe work caused flooding, erosion, and loss of property value.
The Dudleys obtained a 30-day court-ordered extension to answer; they served their answer, discovery, and requests for admissions on the same day.
Sanford’s counsel failed to respond to the requests for admissions within 30 days, believing (mistakenly and subjectively) there was an agreed extension; the requests were therefore deemed admitted under M.R.C.P. 36.
The Dudleys moved for summary judgment eight days after the admissions were due; Sanford served late answers and moved to withdraw the deemed admissions under Rule 36(b) eight days later.
The circuit court denied Sanford’s Rule 36(b) motion and granted summary judgment; Sanford appealed.
The Court of Appeals reversed and remanded, holding the court abused its discretion by failing to permit withdrawal where Rule 36(b)’s two-prong test was satisfied and no prejudice to the Dudleys was shown.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court should permit withdrawal/amendment of deemed admissions under M.R.C.P. 36(b)	Sanford argued withdrawal would serve the presentation of the merits, she moved promptly, and Dudleys would not be prejudiced	Dudleys argued Rule 36 must be strictly enforced; deemed admissions final and summary judgment appropriate	Withdrawal should have been permitted: first prong (presentation of merits) met and second prong (no prejudice) not shown; trial court abused discretion in denying relief
Whether denial was an abuse of discretion when counsel’s untimely response was due to a subjective mistake and the case was at an early stage	Sanford emphasized prompt corrective action (16 days after due date; 8 days after SJ motion) and early-stage litigation	Dudleys relied on precedent upholding strict enforcement where plaintiffs delayed or failed to move timely	Court held the facts (short delay, early stage, no demonstrated prejudice) distinguish prior cases and support allowing withdrawal; denying relief was arbitrary/abuse of discretion

DeBlanc v. Stancil, 814 So. 2d 796 (Miss. 2002) (Rule 36(b) allows withdrawals to avoid draconian results; courts should apply its two-prong test)
Young v. Smith, 67 So. 3d 732 (Miss. 2011) (discusses trial court discretion under Rule 36(b) and limits of precedential holdings)
Sawyer v. Hannan, 556 So. 2d 696 (Miss. 1990) (upholding denial where party significantly delayed and failed to follow proper procedure)
Earwood v. Reeves, 798 So. 2d 508 (Miss. 2001) (warning that parties should know severe consequences of failing to timely respond to requests for admission)
Rainer v. Wal-Mart Assocs. Inc., 119 So. 3d 398 (Miss. Ct. App. 2013) (Rule 36 serves to narrow issues by deeming unresponded matters admitted)