Mississippi State Federation of Colored Women's Club Housing for the Elderly in Clinton, Inc. v. in the Interest of L.R., 62 So. 3d 351

Eleven-year-old L.R. was raped multiple times by Tony Kelly at Federation Tower; she became pregnant and gave birth to a child.
Parents sued Federation and Southern Management for premises liability and related damages; jury awarded $200,000 total with 40% fault to Federation and 60% to L.R.'s father.
Trial court added $800,000 (additur) but publishers did not accept; judgment was challenged on appeal.
L.R. claimed evidentiary errors (consent, prior molestation, damages) and improper fault allocation to her father; Federation challenged additur and other rulings.
Mississippi Supreme Court addressed motions in limine, evidentiary issues, fault allocation, and additur, ultimately reversing and remanding for entry of $200,000 against Federation.
Majority remanded to enter final judgment consistent with jury verdict; additur was found improper and new-trial relief denied on other grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Consent evidence admissibility	LR contends consent evidence is improper due to statute and prejudicial.	Federation argues consent has limited relevance; civil trial rules govern admissibility.	Consent evidence properly admitted for causation/damages; not reversible error.
Economic cost of raising a child	Damages may include cost of rearing the child born from the rape.	Costs of rearing a child should not be recoverable; benefits offsetting applies.	Evidence of rearing costs excluded; majority rule denies child-rearing damages.
Hearsay objections to expert Bishop	Bishop could relay L.R.'s statements for credibility.	Hearsay objections should limit such testimony.	No reversible error; testimony limited but not prejudicial.
Directed verdict on mother's emotional distress	Mother's emotional distress claims warranted beyond simple worry.	Evidence insufficient under Adams v. U.S. Homecrafters.	Directed verdict upheld; no error.
Apportionment of fault to the father	Fault cannot be allocated to LR's father given evidence.	Allocation to a nonparty or parent may be permissible based on facts.	Trial court reversal of fault allocation to LR's father affirmed; fault allocation to parent improper.

Adams v. U.S. Homecrafters, Inc., 744 So.2d 736 (Miss. 1999) (emotional-distress damages and admissibility standards)
Summers v. St. Andrew's Episcopal Sch., Inc., 759 So.2d 1203 (Miss. 2000) (by-stander and emotional-distress framework; Dillon factors)
Dorrill v. State Highway Comm'n of Miss., 525 So.2d 1333 (Miss. 1988) (requirements for additur/remittitur; findings needed)
Glover v. Jackson State Univ., 968 So.2d 1267 (Miss. 2007) (imputation of knowledge to employer in causation)
Stavroula S. v. Guerriera, 193 A.D.2d 796 (N.Y. App. Div. 1993) (consent in civil battery cases; admissibility varies by tort)
Bjerke v. Johnson, 727 N.W.2d 183 (Minn. Ct. App. 2007) (majority view excluding minor-consent in civil statutory rape cases)