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Johnson v. Sysco Food Services
86 So. 3d 242
| Miss. | 2012
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Background

  • Amendment to Miss. Code Ann. § 71-3-51 in 2011 allows direct Supreme Court appeals from the Workers’ Compensation Commission.
  • Johnson’s 2011 Commission decision denied benefits; he appealed directly to the Mississippi Supreme Court.
  • The Majority considers whether Article 6, Section 146 permits direct appeals from the Commission and whether the Court has jurisdiction.
  • The Court analyzes whether the Commission is a quasijudicial tribunal and whether direct appellate review is constitutionally authorized.
  • Section 71-3-51 is a general-law provision; the issue is whether it conforms to constitutional jurisdiction limits.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether Article 6, §146 authorizes direct appeals from the Commission Johnson: direct appeal violates §146 State: §146 permits general-law expansion Yes; constitutional authorization exists
Whether §71-3-51, as amended, is constitutional Johnson: amendment valid under §146 State: valid general-law extension Constitutional under §146
Whether the Court has appellate jurisdiction over direct Commission appeals Johnson: jurisdiction to hear direct appeals State: jurisdiction exists via amendment Court has appellate jurisdiction over direct Commission appeals
Scope of the Court’s remedy and disposition on direct appeal Johnson: direct reversal permissible State: remand/affirmation framework appropriate Review limited to merits; assign to Court of Appeals; briefing schedule set

Key Cases Cited

  • Dodd v. Illinois Central Railroad Co., 105 Miss. 23 (Miss. 1913) (direct appeal limitations; final judicial decision requirement)
  • Glenn v. Herring, 415 So.2d 695 (Miss. 1982) (final decree requirement; jurisdictional limits under §146)
  • Herring v. State, 415 So.2d 697 (Miss. 1982) (final decree and appellate jurisdiction analysis)
  • Gregg v. Natchez Trace Elec. Power Ass'n, 64 So.3d 473 (Miss. 2011) (review limited to substantial evidence; not direct administrative appeal")
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Case Details

Case Name: Johnson v. Sysco Food Services
Court Name: Mississippi Supreme Court
Date Published: May 3, 2012
Citation: 86 So. 3d 242
Docket Number: No. 2011-WC-01086-SCT
Court Abbreviation: Miss.