Tyson Breeders, Inc., et al. v. Harrison
| Docket Number: | 2005-IA-02317-SCT | |
| Supreme Court: | Opinion Link Opinion Date: 10-19-2006 Opinion Author: SMITH, C.J. Holding: VACATED AND REMANDED |
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| Additional Case Information: |
Topic: Contract - Subject matter jurisdiction Judge(s) Concurring: WALLER, P.J., CARLSON AND DICKINSON, JJ. Dissenting Author : Diaz, Easley and Graves, JJ. Concur in Part, Dissent in Part 1: Randolph, J., Concurs in Part and Dissents in Part Without Separate Written Opinion Concurs in Result Only: COBB, P.J. Procedural History: Summary Judgment Nature of the Case: CIVIL - CONTRACT |
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| Trial Court: |
Date of Trial Judgment: 11-28-2005 Appealed from: Covington County Chancery Court Judge: J. Larry Buffington Disposition: Granted partial summary judgment in favor of Appellee Case Number: 02-356 |
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| Party Name: | Attorney Name: | |||
| Appellant: | TYSON BREEDERS, INC., STAN VARNER AND MACK WALKER |
LEWIS W. BELL, G. DAVID GARNER |
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| Appellee: | JAMES ERIC HARRISON | AUDRY REGNAL BLACKLEDGE, DAVID SHOEMAKE, JOHN DUDLEY BUTLER |
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Synopsis provided by:  If you are interested in subscribing to the weekly synopses of all Mississippi Supreme Court and Court of Appeals hand downs please contact Tammy Upton in the MLI Press office. |
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| Topic: | Contract - Subject matter jurisdiction |
| Summary of the Facts: | James Eric Harrison filed suit against Tyson Breeders, Inc., seeking relief, including specific performance, injunctive relief, and actual and punitive damages, from Tyson, and alleging that Tyson is responsible for damages he sustained when Tyson allegedly failed to abide by their Hatch Egg Production Contract. The chancellor granted partial summary judgment to Harrison on Harrison’s breach of contract claim and transferred the remaining issue of damages to the Circuit Court of Covington County for a trial to determine damages. Tyson petitioned the court for interlocutory appeal, which was granted. |
| Summary of Opinion Analysis: | Tyson argues that despite inclusion of purported “equitable” claims, a complaint seeking actual and punitive damages and asserting claims for fraud, fraudulent inducement, breach of contract and negligence is clearly legal in nature and should be heard in circuit court to preserve the right of trial by jury. Tyson also argues that jurisdiction over a breach of contract action rests in circuit and not chancery court, and the remedy on interlocutory appeal is to order the transfer of the case from chancery to circuit court. Finally, Tyson argues that since the contract sought to be specifically enforced expired on December 31, 2002, there is no longer a contract upon which specific performance can be granted. In cases in which some doubt exists as to whether a complaint is legal or equitable in nature, the better practice is to try the case in circuit court. Although the Court has previously allowed a chancery court to retain jurisdiction over cases involving questions of both law and equity, more recent cases hold that equitable claims are more appropriately brought before a circuit court when they are connected to a contractual relationship or other claims tied to questions of law. This case does not involve an unique matter such as real estate where specific performance is a particularly appropriate remedy. Rather, the equitable remedy sought by Harrison in his complaint involved the specific performance of a contract for services, which expired on December 31, 2002. Even the chancellor’s order demonstrates that specific performance is not the more appropriate remedy in this matter, as the order also acknowledges an adequate remedy at law to recover damages. Therefore, the proper remedy for Harrison’s action for breach of contract is at law to recover damages, which is best heard by the circuit court. Alternatively, Tyson argues that genuine issues of material fact exist concerning Harrison’s failure to perform under the agreement. Having found that the chancery court lacked proper jurisdiction to hear Harrison’s breach of contract claims, Harrison was thus not entitled to judgment as a matter of law concerning those claims. Harrison’s claims include contractual questions of law and equity, request punitive damages and because having the claims adjudicated in chancery court would deprive Tyson of the right to a jury trial, the chancellor erred in failing to transfer the matter to circuit court. |
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