City of Grenada, Mississippi v. Frank Marascalco, Mike Hyneman, Bill Williams and Joseph Lee

Summary

The Supreme Court of Mississippi considered two consolidated appeals arising from the City of Grenada's proposed deannexation of territory and related Voting Rights Act preclearance proceedings. The court affirmed the chancery court's denial of the deannexation and its contempt judgment against the City and certain councilmen, but reversed and rendered the order requiring the City to submit a supplemental Section 5 preclearance filing. The court held that the voting-rights controversy did not displace Mississippi's established reasonableness analysis for deannexation and that the chancery court lacked authority to order the municipality to litigate in a specified manner.

Holdings

1. The chancery court properly applied Mississippi's established annexation reasonableness analysis to the proposed deannexation and did not err in denying the City's request.
2. The chancery court lacked authority to order a municipal body to initiate or continue litigation before the United States Attorney General in a specified manner.
3. The chancery court did not err in holding the City and four councilmen in contempt.

Questions Presented

1. Whether the chancery court applied an incorrect legal standard in denying the City's deannexation ordinance enacted in response to the United States Attorney General's Section 5 objections.
2. Whether the chancery court violated due process by ordering the City to file a supplemental Section 5 preclearance submission.
3. Whether the chancery court erred in holding the City and four councilmen in contempt for failing to supplement the preclearance request.
4. Whether the City's notice of appeal automatically stayed the chancery court's judgment under Mississippi's municipal-boundary statutes.

Disposition

other