University of Southern Mississippi v. Davida Dawn Williams

Summary

The Supreme Court of Mississippi reviewed a jury verdict awarding Davida Dawn Williams $800,000 against the University of Southern Mississippi and university professors arising from alleged misconduct affecting her doctoral studies. The court held that the defendants were entitled to judgment notwithstanding the verdict on Williams’s 42 U.S.C. § 1983 and Mississippi Tort Claims Act claims, but that her breach-of-contract claim could proceed. It reversed the judgment and remanded for a new trial limited to damages on the contract claim.

Holdings

1. JNOV should have been granted on Williams's § 1983 claim because the only remaining defendants were the State university and professors sued in their official capacities, none of whom qualified as a person subject to suit under § 1983.
2. The student-university relationship is contractual in nature, and sufficient evidence supported a jury finding that USM breached its contractual duty of good faith and fair dealing; therefore, denial of JNOV on the contract claim was affirmed.
3. A plaintiff may recover mental-anguish and emotional-distress damages in a breach-of-contract action without proof of physical manifestation or, in every case, expert testimony, but must prove that the distress was foreseeable and that the plaintiff actually suffered specific mental anguish during a specific time period.
4. JNOV should have been granted on the Mississippi Tort Claims Act claim because Williams did not file the required notice of claim, the limitations period had expired, and any recovery under the Act was barred.
5. The damages award was too speculative and unsupported by sufficient evidence, requiring reversal and a new trial limited to damages arising from USM's breach of contract.

Questions Presented

1. Whether the defendants were entitled to JNOV on Williams's 42 U.S.C. § 1983 claim because only the university and professors in their official capacities remained as defendants.
2. Whether the defendants were entitled to JNOV on Williams's breach of contract claim.
3. Whether the Mississippi Tort Claims Act provided the exclusive remedy for the tort-related harms and barred recovery because Williams did not comply with the Act's notice requirements.
4. Whether the jury's $800,000 damages award was too speculative and required reversal and a new trial.

Disposition

reversed_and_remanded