Sonja Renee Baggett v. James Darrell Baggett
246 So. 3d 887
| Miss. Ct. App. | 2017Background
- Renee and James Baggett married in 1998; they raised Renee’s children and an adopted grandchild.
- James worked on oil rigs with alternating two-week rotations and drank while home; witnesses described regular drinking and occasional drunken episodes.
- Renee alleged long-term emotional abuse, intermittent physical abuse (including an August 2006 domestic-violence arrest), and sought divorce for habitual cruel and inhuman treatment and habitual drunkenness; she alternatively pleaded irreconcilable differences.
- At bench trial Renee, James, and six lay witnesses testified; most witnesses reported frequent arguments, concern about James’s drinking, and some observed intoxication; only the 2006 incident involved clearly observed physical injury.
- Renee attempted to introduce a deposition of Dr. Bharat Patel (medical testimony regarding her conditions), but the chancellor excluded it as untimely notice and because opposing counsel did not attend.
- After excluding the deposition the chancellor granted James’s Rule 41(b) motion and dismissed Renee’s complaint; he also awarded joint custody and child support. Renee appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether chancery court erred in dismissing complaint under Rule 41(b) | Renee: presented overwhelming evidence of habitual cruel and inhuman treatment and habitual drunkenness | James: evidence insufficient to prove pattern of cruelty or habitual drunkenness | Affirmed: dismissal upheld; evidence insufficient to show required pattern for cruelty or level of drunkenness required for divorce |
| Whether chancellor should have made separate findings of fact and conclusions of law under Rule 52(a) | Renee: case was hotly contested and required specific findings | James: Renee never requested findings; chancery court acted within discretion | Affirmed: no error—Renee did not request findings and facts weren’t so complex or disputed as to require them sua sponte |
| Whether exclusion of Dr. Patel’s deposition was error | Renee: deposition was admissible and necessary to show medical/mental impact | James: deposition notice was untimely (1 day) and counsel could not attend | Affirmed: exclusion not an abuse of discretion—deposition was effectively a statement without opposing counsel present |
| Standard of appellate review for bench dismissal and legal rulings | Renee: contends chancellor misapplied law and ignored weight of evidence | Court: applies substantial-evidence/manifest-error for factual findings and de novo for legal questions | Affirmed: chancellor’s factual findings supported; legal standards applied correctly |
Key Cases Cited
- Lomax v. Lomax, 172 So. 3d 1258 (Miss. Ct. App.) (standard of review for chancery factual findings)
- Smith v. Smith, 90 So. 3d 1259 (Miss. Ct. App.) (de novo review for legal determination of habitual cruelty)
- Stewart v. Merchants Nat’l Bank, 700 So. 2d 255 (Miss.) (Rule 41(b) dismissal standard and judge’s role in weighing evidence)
- Horn v. Horn, 909 So. 2d 1151 (Miss. Ct. App.) (elements and required pattern for habitual cruel and inhuman treatment)
- Sproles v. Sproles, 782 So. 2d 742 (Miss.) (examples of drunkenness and abuse sufficient for divorce)
- Lee v. Lee, 154 So. 3d 904 (Miss. Ct. App.) (habitual drunkenness elements and application)
- Robinson v. Lee, 821 So. 2d 129 (Miss. Ct. App.) (trial court discretion to admit deposition testimony)
- Tricon Metal & Services, Inc. v. Topp, 516 So. 2d 236 (Miss.) (when courts should make specific findings of fact and conclusions of law)