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