William W. Satterfield v. State of Mississippi
158 So. 3d 380
| Miss. Ct. App. | 2015Background
- William Satterfield, a DHS child-support enforcement attorney, sued the State and various officials alleging underpayment and statutory violations related to funds/salary for child-support attorneys.
- He sought relief including damages, an accounting, injunction, and mandamus.
- The Hinds County Chancery Court granted the State’s Rule 12(b)(6) motion to dismiss for failure to state a claim.
- Satterfield appealed pro se, raising multiple overlapping and poorly articulated claims.
- The Court of Appeals reviewed de novo and required Satterfield to show he had pleaded viable causes of action and to identify elements and supporting facts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Violation of statute (fund segregation, salary-setting statutes) | Statutes (e.g., Miss. Code §§ 43-19-37, 43-19-61) require a special fund and pay practices that would support higher salaries; current commingling deprives him of pay | Alleged statutory violations do not, by themselves, create a cognizable cause of action or show entitlement to relief | Dismissed — statutory-violation labels alone are not a cognizable cause of action and Satterfield failed to plead a viable claim |
| Injunction / Mandamus | Seeks mandamus/injunction to compel statutory compliance and fund/accounting | No standing and plaintiff failed to plead elements for mandamus or injunctive relief | Dismissed — plaintiff abandoned these remedies on appeal and failed to show entitlement |
| Negligence (based on statutory duties) | DHS’s statutory failures constitute negligence and entitle him to tort relief | Even if statutes were violated, they don’t establish a tort duty or standard of care; negligence elements not pleaded | Dismissed — negligence claims abandoned; statutes cited do not create a tort duty or standard of care as pleaded |
| Accounting; transfer of court; leave to amend | Seeks accounting; contends chancery court erred by not transferring to circuit court and by denying leave to amend | Transfer argument irrelevant where dismissal on merits is correct; amendment would be futile; accounting claim not briefed | Dismissed/denied — no reversible error. Transfer contention fails; denial of leave to amend proper because amendment would be futile; accounting claim not pursued on appeal |
Key Cases Cited
- Chalk v. Bertholf, 980 So. 2d 290 (Miss. Ct. App. 2007) (Rule 12(b)(6) tests legal sufficiency of a complaint)
- Little v. Mississippi Dep’t of Transp., 129 So. 3d 132 (Miss. 2013) (de novo review for legal issues)
- Entergy Miss., Inc. v. Richardson, 134 So. 3d 287 (Miss. 2014) (appellate review may affirm for any correct reason)
- Jordan v. State, 995 So. 2d 94 (Miss. 2008) (appellant bears burden to show reversible error)
- Jefferson v. State, 138 So. 3d 263 (Miss. Ct. App. 2014) (appellant must adequately brief issues; court will not act as advocate)
- Palmer v. Biloxi Reg’l Med. Ctr., 564 So. 2d 1346 (Miss. 1990) (negligence requires duty, breach, causation, injury)
- McLean v. Green, 352 So. 2d 1312 (Miss. 1977) (jurisdictional transfer principles)
- Merideth v. Merideth, 987 So. 2d 477 (Miss. Ct. App. 2008) (leave to amend may be denied as futile)