Larry Jarrett v. Robert Houston Dillard, 167 So. 3d 1147

In 1997 the Mississippi Workers’ Compensation Commission found Roy Dillard’s injury compensable and awarded disability and medical benefits; the Court of Appeals affirmed and mandate issued in 2000.
Dillard’s counsel raised Jarrett’s personal liability (president/majority shareholder of Dixie Products) in 2001 but no adjudication of Jarrett’s individual liability occurred before Dillard’s death in 2005.
An Administrative Judge later entered a final award (amended in 2008) finding permanent total disability and awarding approximately $125,000 plus interest and medical expenses; no appeal was taken from that award.
The Estate (executor Robert Dillard) sued Jarrett and Dixie Products in circuit court in 2009 to enforce the compensation judgment and to hold Jarrett personally liable under Miss. Code Ann. § 71‑3‑83(1).
The circuit court granted summary judgment enforcing the judgment jointly and severally against Dixie and Jarrett; the Court of Appeals reversed on res judicata and statute‑of‑limitations grounds; the Mississippi Supreme Court granted certiorari.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether claim preclusion (res judicata) bars enforcing the workers’ compensation judgment against Jarrett personally	Dillard: judgment against Dixie may be enforced against Jarrett because he controlled litigation, acted as Dixie’s alter ego, and §71‑3‑83(1) makes officers personally liable	Jarrett: prior proceedings put Jarrett’s individual liability at issue in 2001 and thus claim preclusion or lack of opportunity to litigate bars subsequent suit	Court: Not barred—judgment against Dixie can be enforced against Jarrett because he was president/majority shareholder, controlled prior litigation, acted as alter ego, and statute imposes officer liability
Whether the statute of limitations barred the enforcement action	Dillard: suit filed within the seven‑year enforcement period measured from the final award	Jarrett: limitations and prior delay bar the claim	Court: Limitations did not bar the suit—final award was in Feb. 2008 and the suit filed June 2009 was timely

New Hampshire v. Maine, 532 U.S. 742 (discussing claim preclusion and same‑claim concepts)
Marrese v. American Academy of Orthopaedic Surgeons, 470 U.S. 373 (scope of matters that should have been raised earlier)
Zenith Radio Corp. v. Hazeltine Research, Inc., 395 U.S. 100 (limits of enforcing judgments only against named defendants absent special circumstances)
Taylor v. Sturgell, 553 U.S. 880 (when a nonparty can be bound by prior litigation that she controlled)
Dudley v. Smith, 504 F.2d 979 (allowing enforcement of corporate judgments against officers who were alter egos/controlled litigation)
Alman v. Danin, 801 F.2d 1 (similar rule for officer liability where corporate form disregarded)
Matthews Construction Co. v. Rosen, 796 S.W.2d 692 (Tex.) (piercing corporate veil to bind officers to corporate judgments)
Thames & Co. v. Eicher, 373 So. 2d 1033 (Miss.) (alter ego doctrine and disregarding corporate form)
Beco, Inc. v. American Fidelity Fire Insurance Co., 370 So. 2d 1343 (Miss.) (corporate veil considerations)