Pascagoula-Gautier School District v. Board of Supervisors of Jackson County, 212 So. 3d 742

Background

Jackson County leased property to Chevron under long-term in-lieu-of-tax agreements; the property sat in the Pascagoula-Gautier School District (PGSD) but outside City limits.
PGSD discovered the leasehold remained on in-lieu rolls beyond statutory limits; county later moved the leasehold to regular tax rolls and the assessor valued the leasehold at 50% of land value.
PGSD and City of Pascagoula appealed the Board of Supervisors’ approval of the assessor’s methodology, alleging arbitrary valuation and reduced tax revenue to PGSD.
The Board and Chevron sought dismissal for lack of standing; the trial court initially denied dismissal but later (sua sponte) dismissed for lack of standing, reasoning that Miss. Code § 11-51-77 did not expressly authorize PGSD/City to appeal.
Circuit court granted the Board’s jury-demand under § 11-51-77; PGSD moved to join Chevron as a party and the trial court denied joinder.
Supreme Court: reversed dismissal (PGSD and City have standing), affirmed jury-trial ruling, and reversed denial of Chevron joinder (majority disagreed on rationale: Rule 19 necessity vs. Chevron waiver by participation).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing to appeal tax assessment	PGSD/City: as direct recipients/taxing authority they suffer an adverse effect different from general public and have statutory duties to secure funding	Board: § 11-51-77 does not authorize PGSD/City to sue; only taxpayer/authorized officials can appeal; permitting third parties would open floodgates	Court reversed dismissal: Mississippi standing doctrine is liberal; PGSD/City showed an adverse effect distinct from general public and thus have standing
Right to jury trial on de novo tax appeal	PGSD/City opposed jury; argued statutory de novo review should be bench	Board demanded jury under § 11-51-77	Supreme Court affirmed grant of jury trial (citing Riverboat)
Joinder of Chevron as a party	PGSD: Chevron should be joined under Rule 19 or Rule 20 because its absence risks double litigation and Chevron has an interest	Board/Chevron: Chevron opposed joinder; county took no position; argued joinder unnecessary	Majority reversed denial of joinder and remanded. A majority agreed joinder was required, but split on rationale (some invoked Rule 19 compulsory joinder; others held Chevron waived objection by extensive participation)
Whether Chevron waived right to object to joinder by participation	PGSD: Chevron’s extensive, substantive participation amounted to waiver of nonparty status	Chevron: never moved to intervene and opposed joinder	Court: plurality view — Chevron’s conduct could be treated as waiver (some justices disagreed); overall court ordered joinder but did not produce a single majority rationale on waiver vs. Rule 19 necessity

Key Cases Cited

SASS Muni. V, LLC v. DeSoto County, 170 So.3d 441 (Miss. 2015) (describes Mississippi’s liberal standing tests and standards)
Pascagoula School Dist. v. Tucker, 91 So.3d 598 (Miss. 2012) (school-district tax distribution statute found unconstitutional; context on ad valorem distribution)
Riverboat Corp. of Miss. v. Harrison Cty. Bd. of Supervisors, 198 So.3d 289 (Miss. 2016) (addresses jury-trial entitlement in de novo tax-assessment appeals)
City of Belmont v. Miss. State Tax Comm’n, 860 So.2d 289 (Miss. 2003) (standing and whether a statute must expressly authorize municipal suits)
State v. Quitman County, 807 So.2d 401 (Miss. 2001) (permissive stance on standing to review governmental actions)