Mississippi Baptist Medical Center v. Sylvia Dianne Harkins, 245 So. 3d 370

Dianne and Reggie Harkins sued multiple healthcare providers after Dianne developed sepsis and gangrene, resulting in amputation of her hands and feet; some alleged negligent acts occurred in Leake County and some in Hinds County.
Madden Medical Clinic and Dr. David Moody (Leake County defendants) moved to dismiss or to sever and transfer venue to Leake County under Miss. Code § 11-11-3(3); BMC‑Leake and Baptist Health made similar motions.
The Hinds County circuit court denied the motions; the Leake County defendants appealed interlocutorily and appeals were consolidated.
Central statutory provision: Miss. Code Ann. § 11-11-3(3) (medical‑malpractice suits "shall be brought only in the county in which the alleged act or omission occurred").
Lower court and parties disputed whether (1) § 11-11-3(3) is plain and unambiguous and (2) it forbids joinder of medical defendants whose alleged malpractice occurred in different counties.

Issue	Plaintiff's Argument (Harkins)	Defendant's Argument (Leake County Defs.)	Held
Whether § 11-11-3(3) is plain and unambiguous	Statute limits venue to a county where an alleged act/omission occurred but can allow choosing among counties that satisfy the statute	Statute is plain: venue for a medical defendant is only the single county where that defendant’s alleged malpractice occurred	§ 11-11-3(3) is plain and unambiguous, but its singular wording can encompass multiple counties when separate acts/omissions occurred in different counties and produce an indivisible injury
Whether § 11-11-3(3) prevents joinder of medical defendants with alleged acts in different counties	Rule 20 and Rule 82(c) permit permissive joinder and then the suit may be filed in any county where any one claim could have been brought; severance would prevent complete relief	Joinder cannot cure venue; a defendant whose acts occurred only in Leake County cannot be haled into Hinds County under § 11-11-3(3)	§ 11-11-3(3) does not bar permissive joinder where all joined defendants are medical providers falling within the same venue category; Rule 82(c) allows suit in either county that satisfies § 11-11-3(3)

Laurel Ford Lincoln‑Mercury, Inc. v. Blakeney, 81 So.3d 1123 (Miss. 2012) (standard of review: venue rulings reviewed for abuse of discretion; statutory questions de novo)
Hedgepeth v. Johnson, 975 So.2d 235 (Miss. 2008) (same de novo principle for statutory interpretation)
Miller v. French, 530 U.S. 327 (U.S. 2000) (statutory words considered in context; interpret the statute as a whole)
In re Settoon Towing, L.L.C., 859 F.3d 340 (5th Cir. 2017) (consider statute language as a whole when construing meaning)
Lawson v. Honeywell Int'l, Inc., 75 So.3d 1024 (Miss. 2011) (court’s role is to determine what a statute provides, applying plain meaning if unambiguous)
Miss. Methodist Hosp. & Rehab. Ctr., Inc. v. Miss. Div. of Medicaid, 21 So.3d 600 (Miss. 2009) (statutory interpretation when text is ambiguous or silent)
Am. Home Prods. Corp. v. Sumlin, 942 So.2d 766 (Miss. 2006) (plaintiff may choose among permissible venues listed in venue statute)
Adams v. Baptist Mem'l Hosp.‑DeSoto, Inc., 965 So.2d 652 (Miss. 2007) (discusses effect of "notwithstanding" in §11‑11‑3 but involved a medical and nonmedical defendant)
Pitalo v. GPCH‑GP, Inc., 933 So.2d 927 (Miss. 2006) (apply plain meaning when statute is not ambiguous)
Salts v. Gulf Nat'l Life Ins. Co., 743 So.2d 371 (Miss. 1999) (statutes set venue)
Bd. of Trustees of State Inst. of Higher Learning v. Van Slyke, 510 So.2d 490 (Miss. 1987) (legislature controls venue settings)