Ralph Arnold Smith, Jr. v. State of MississippiRalph Arnold Smith, Jr. v. State of Mississippi
BEFORE GRIFFIS, P.J., ISHEE AND GREENLEE, JJ.
¶1. The Leflore County Chancery Court granted a petition to have Ralph Arnold Smith Jr. involuntarily committed for inpatient treatment in the Mississippi State Hospital at Whitfield (Whitfield). Smith‘s counsel subsequently filed a petition for outpatient treatment in the Rankin County Chancery Court. After finding that the Hinds County Chancery Court had jurisdiction over the petition, the Rankin County Chancery Court dismissed his petition. Smith appeals. Finding no error, we affirm.
STATEMENT OF FACTS AND PROCEDURAL HISTORY
¶2. After facing criminal charges in 2012, the Leflore County Circuit Court determined that Smith was not competent to stand trial. On January 6, 2015, the Leflore County Chancery Court held that Smith should be involuntarily committed to Whitfield.1 In February 2015, Smith‘s counsel requested “a hearing on the question of [Smith‘s] commitment for further treatment,” pursuant to
¶3. Displeased with the Hinds County Chancery Court‘s order of continued treatment, Smith‘s counsel returned to the Leflore County Chancery Court and filed additional motions seeking outpatient treatment and other forms of relief to have Smith released from Whitfield. On July 30, 2015, however, the Leflore County Chancery Court entered a final judgment,
¶4. The State moved to dismiss Smith‘s petition for outpatient treatment. The State argued that because Smith was committed to Whitfield, the Hinds County Chancery Court was statutorily required to hear a petition for outpatient treatment. In addition, the State noted that the Hinds County Chancery Court had already found that Smith required further inpatient treatment, and Smith did not appeal that order. The Rankin County Chancery Court agreed that it lacked jurisdiction. Consequently, it granted the State‘s motion to dismiss. Smith appeals. During the pendency of this appeal, Smith successfully petitioned the Hinds County Chancery Court‘s release from Whitfield for outpatient treatment.
DISCUSSION
I. Smith‘s case falls under the exception to the mootness doctrine, “capable of repetition yet evading review.”
¶5. Because Smith has been released from Whitfield, this Court is faced with an appeal that could be considered moot. Generally, this Court will dismiss an appeal “when no useful purpose could be accomplished by entertaining it, when so far as concerns any practical ends to be served the decision upon the legal questions involved would be merely academic.” Strong v. Bostick, 420 So. 2d 1356, 1359 (Miss. 1982). Exceptions to the mootness doctrine, however, do exist. As such, we may address appeals considered moot where the matter is “capable of repetition yet evading review.” In re Bauman, 878 So. 2d 1033, 1037 (¶15) (Miss. Ct. App. 2004) (civil-commitment action where appellant was discharged prior to adjudication of his appeal, but held appeal fell under “capable of repetition yet evading review” exception); see also Weinstein v. Bradford, 423 U.S. 147, 149 (1975). An appeal that is “capable of repetition yet evading review,” though moot, must possess two qualities:
(1) the challenged action was in its duration too short to be fully litigated prior to its cessation or expiration; and (2) there was a reasonable expectation that the same complaining party would be subject to the same action again. Bauman, 878 So. 2d at 1037 (¶15) (citing Strong, 420 So. 2d at 1359).
¶6. Applying the precedent set forth in Bauman, we find that Smith‘s appeal falls within the purview of the “capable of repetition yet evading review” exception to the mootness doctrine. Smith‘s commitment, though over a year in duration, does not defeat the first prong of this exception, as the subject of this appeal is the Rankin County Chancery Court‘s dismissal of Smith‘s petition for outpatient treatment, which Smith timely appealed while committed. We find that the challenged action was too short in its duration to be fully litigated prior to its cessation or expiration. We also find that there is a reasonable expectation that Smith could be subject to the same action again. This is because Smith asserts that Hinds County did not, and does not, have proper jurisdiction over his petition for outpatient treatment, but that court ultimately granted the relief that Smith sought. Thus, we
¶7. Lastly, this Court finds the present matter involves a question affecting the public interest. “[T]here is an exception to the general rule as respects moot cases, when the question concerns a matter of such a nature that it would be distinctly detrimental to the public interest that there should be a failure by dismissal to declare and enforce a rule for future conduct.” Bauman, 878 So. 2d at 1038 (¶18) (citing Alfred v. Webb, 641 So. 2d 1218, 1220 (Miss. 1994)). Thus, we find the possible conflict regarding which court has
jurisdiction under the circumstances necessitates that this Court address the public interest at issue.
II. The Rankin County Chancery Court did not err as a matter of law in granting the State‘s motion to dismiss.
¶8. The primary issue in this appeal is which court has jurisdiction over a request for outpatient treatment of someone who has been involuntarily committed for inpatient treatment at Whitfield. A de novo standard of review is employed by this Court when reviewing a trial court‘s grant or denial of a motion to dismiss. Tallahatchie Gen. Hosp. v. Howe, 154 So. 3d 29, 31 (¶7) (Miss. 2015). “Questions of jurisdiction and statutory interpretation . . . present matters of law reviewed de novo.” Leg. of State v. Shipman, 170 So. 3d 1211, 1214 (¶10) (Miss. 2015). Reviewing the statutes at issue, we find the Rankin County Chancery Court did not err as a matter of law in granting the motion to dismiss.
¶9. The question turns on the correlation between sections 41-21-74(4) and 41-21-83. Section 41-21-74(4) relates to “outpatient treatment,” and provides that:
The chancery court of the county where the public facility is located or the committing court shall have jurisdiction over matters concerning outpatient commitments when such an order is sought subsequent to an inpatient course of treatment pursuant to Sections 41-21-61 through 41-21-107, 43-21-611, 99-13-7 and 99-13-9 . . . .
(Emphasis added). Smith expressly sought relief pursuant to
housed in Rankin County at Whitfield at the time of his petition. Smith further asserts that because Leflore County closed his case, Rankin County is alternatively the only court with proper jurisdiction under the statute.
¶10. The State, however, asserts otherwise through its reading of
If a hearing is requested as provided in [s]ection 41-21-74, 41-21-81 [(Rev. 2013),] or 41-21-99 [(Rev. 2013)], the court shall not make a determination of the need for continued commitment unless a hearing is held and the court finds by clear and convincing evidence that (a) the person continues to have mental illness or have an intellectual disability; and (b) involuntary commitment is necessary for the protection of the patient or others; and (c) there is no alternative to involuntary commitment.
Hearings held under this section shall be held in the chancery court of the county where the facility is located; however, if the patient is confined at the Mississippi State Hospital at Whitfield, Mississippi, the hearing shall be conducted by the Chancery Court of the First Judicial District of Hinds County, Mississippi.
(Emphasis added). The State, therefore, argues, as it did in its motion to dismiss, that based upon the language of
¶11. This Court has clearly articulated its standards for interpreting a statute. “The most fundamental rule of statutory construction is the plain[-]meaning rule, which provides that if a statute is not ambiguous, then this Court must apply the statute according to its terms.” Buckel v. Chaney, 47 So. 3d 148, 158 (¶35) (Miss. 2010) (quoting State ex rel. Hood v. Madison Cty. Bd. of Supervisors, 873 So. 2d 85, 90 (¶19) (Miss. 2004)). “Likewise, it is a well-settled rule of statutory construction that when two statutes pertain to the same subject,
they must be read together in light of legislative intent.” Tunica Cty. v. Hampton Co. Nat‘l Sur., 27 So. 3d 1128, 1133 (¶15) (Miss. 2009) (citing Lenoir v. Madison Cty., 641 So. 2d 1124, 1129 (Miss. 1994)). “The function of the Court is not to decide what a statute should provide, but to determine what it does provide.” Russell v. State, 231 Miss. 176, 181, 94 So. 2d 916, 917 (1957). Statutes “on the same subject, although in apparent conflict, should if possible be construed in harmony with each other to give effect to each.” Tunica Cty., 27 So. 3d at 1134 (¶16) (citing Miss. Gaming Comm‘n v. Imperial Palace of Miss., 751 So. 2d 1025, 1029 (¶15) (Miss. 1999)).
¶12. Heeding these canons of statutory construction, we address the specific statutes at issue in the present matter.
Judicial District of Hinds County, Mississippi.” See
¶13. To rebut the plain language of
¶14. To further support his argument, Smith contends that he did not request a hearing under any provision that is found in
¶15. Thus, reading sections
CONCLUSION
¶16. Employing a de novo standard of review, we find that the Rankin County Chancery Court did not err as a matter of law in dismissing Smith‘s petition for outpatient treatment. Though Whitfield is located in Rankin County and, thus, Rankin County would ordinarily have proper jurisdiction to hear a petition for outpatient treatment under
¶17. THE JUDGMENT OF THE RANKIN COUNTY CHANCERY COURT IS AFFIRMED. ALL COSTS OF THIS APPEAL ARE ASSESSED TO THE APPELLANT.
LEE, C.J., IRVING AND GRIFFIS, P.JJ., FAIR, WILSON, GREENLEE AND WESTBROOKS, JJ., CONCUR. CARLTON, J., CONCURS IN RESULT ONLY WITHOUT SEPARATE WRITTEN OPINION. BARNES, J., NOT PARTICIPATING.