Natchez Hospital Company, LLC v. Adams County Board of Supervisors, 238 So. 3d 1162

Natchez Hospital Company appealed an Adams County Board of Supervisors' ad valorem software tax assessment to circuit court after paying the assessed taxes.
The Board moved to dismiss for lack of jurisdiction because Hospital did not post an appeal bond required by Miss. Code § 11-51-77.
The circuit court granted the Board's motion, finding failure to post the bond deprived the court of jurisdiction.
Hospital argued Title 27 statutes (§§ 27-35-119 and 27-35-121) provide an independent appeal route that does not require the § 11-51-77 bond, especially since § 27-35-121 requires payment of taxes and contemplates collection proceeding during appeals.
The Supreme Court reviewed statutory history and precedent to determine whether posting the bond under § 11-51-77 is mandatory for such appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 11-51-77 bond is mandatory to invoke circuit court jurisdiction on appeals from board equalizations under § 27-35-119	Hospital: Title 27 provisions create an independent appeal path; paying the tax (per § 27-35-121) suffices and bond is not required	Board: Appeal is governed by § 11-51-77; bond is required to perfect appeal and confer jurisdiction	The bond requirement in § 11-51-77 is mandatory; failure to post bond deprives court of jurisdiction
Whether payment of tax substitutes for posting the appeal bond	Hospital: Payment of taxed amount complies with statute and obviates need for bond	Board: Payment of tax does not excuse posting the bond; both requirements coexist	Payment of tax does not excuse the bond; both must be complied with when applicable
Whether § 27-35-119 and § 11-51-77 should be construed together	Hospital: Separate codification implies independent procedures	Board: Historical and caselaw show §§ must be read together to determine appeal procedure	Statutes are construed together; appeal under § 27-35-119 requires compliance with § 11-51-77
Whether circuit court could have jurisdictional discretion to waive bond (left open)	Hospital: Did not explicitly ask waiver but argued bond not required	Board: Did not assert need to address waiver	Court did not decide whether courts may waive or reduce bond; issue not before Court

Moller-Vandenboom Lumber Co. v. Bd. of Supervisors of Attala Cty., 99 So. 823 (Miss. 1924) (statutes governing appeals from board equalizations must be construed together and require posting bond)
Moller-Vonderboom Lumber Co. v. Bd. of Supervisors of Attala Cty., 103 So. 81 (Miss. 1925) (appellant posted bond to perfect appeal following court guidance)
Grenada Bank v. Town of Moorhead, 133 So. 666 (Miss. 1931) (taxpayer must pay taxes but payment does not affect or moot an appeal when bond is posted)
Derr Plantation, Inc. v. Swarek, 14 So. 3d 711 (Miss. 2009) (de novo review standard for jurisdictional dismissal)
Estate of Klaus ex rel. Klaus v. Vicksburg Healthcare, LLC, 972 So. 2d 555 (Miss. 2007) (statutory interpretation reviewed de novo)