Rodney Shelton Fulgham v. Clara Jackson, 234 So. 3d 279

Jackson sued Fulgham for personal injuries and issued summons showing he was incarcerated in Bolivar County.
Within the initial 120-day Rule 4(h) period, Jackson moved for a 120-day enlargement, stating Fulgham had been transferred and was difficult to locate; the court granted it.
Before that first extension expired, Jackson moved for a second 60-day enlargement, explaining prison officials had given conflicting information about Fulgham’s location; the court granted it.
Service was effected on November 12, 2015, within the second extension.
Fulgham moved to dismiss for untimely service, arguing Jackson could have located him via the MDOC website and thus failed to show good cause; the trial court denied the motion after an evidentiary hearing.
On interlocutory appeal, the Mississippi Supreme Court reviewed (1) the proper legal standard for successive pre-expiration enlargements and (2) whether Jackson showed cause/good cause for the second extension.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper standard for second (or subsequent) enlargement of time when the motion is filed before the prior extension expires	Rule 6(b) governs enlargements made before expiration so only "for cause shown" (i.e., "cause") is required, not Rule 4(h)'s "good cause"	Johnson required "good cause" for second extensions; Rule 4(h) controls after 120 days	The Court overruled that portion of Johnson: when a subsequent enlargement is filed before the prior extension expires, Rule 6(b) applies and only "cause" must be shown.
Application to facts — whether Jackson met the required standard (cause) and, alternatively, whether she met "good cause"	Jackson diligently inquired into Fulgham’s whereabouts, relied on prison officials who gave misleading information, timely filed both enlargement motions, and served within the ordered periods	Fulgham argued Jackson was not diligent and could have located him via the MDOC website; therefore no sufficient cause/good cause existed	The trial court did not abuse its discretion: Jackson showed "cause" for the second extension, and court also found "good cause" on the facts (misdirection by prison officials, diligence, mitigating circumstances of incarceration).

Collins v. Westbrook, 184 So. 3d 922 (Miss. 2016) (abuse-of-discretion review for trial court's finding of good cause)
Rains v. Gardner, 731 So. 2d 1192 (Miss. 1999) (deferential review of factual findings on service issues)
Foss v. Williams, 993 So. 2d 378 (Miss. 2008) (distinguishing fact- and law-based denial/grant review; discussion of good-cause factors)
Cross Creek Prods. v. Scafidi, 911 So. 2d 958 (Miss. 2005) (holding that a motion for additional time filed within 120 days requires only cause under Rule 6(b))
Johnson v. Thomas ex rel. Polatsidis, 982 So. 2d 405 (Miss. 2008) (previously required good cause for second extensions; partially overruled here)
Webster v. Webster, 834 So. 2d 26 (Miss. 2002) (discussing excusable neglect and good-cause standard)