Hinds County, Mississippi, City of Jackson, Mississippi, Billy Jade (Jay) Albright in His Individual Capacity, and Mississippi Bureau of Narcotics v. Ronnie Burton

Summary

The Mississippi Supreme Court held that Hinds County, the City of Jackson, the Mississippi Bureau of Narcotics, and Officer Billy Jade Albright were immune under the Mississippi Tort Claims Act. The court applied the police-protection exemption to claims arising from an officer’s use of deadly force while responding to gunfire and applied the inmate exemption to Burton’s false-imprisonment claims against Hinds County. The court reversed the circuit court’s judgment awarding Burton $350,000 and rendered judgment for the defendants.

Holdings

1. The defendants were immune under Mississippi Code section 11-46-9(1)(c) because Burton failed to prove by a preponderance of the evidence that Albright acted in reckless disregard of Burton's safety while performing police-protection duties.
2. Hinds County was immune under Mississippi Code section 11-46-9(1)(m) because Burton was an inmate, including a pretrial detainee, when the false-imprisonment claims against the county arose at the Raymond Detention Center.

Questions Presented

1. Whether Albright, the Mississippi Bureau of Narcotics, the City of Jackson, and Hinds County were immune under the police-protection exemption in Mississippi Code section 11-46-9(1)(c).
2. Whether Hinds County was immune under the inmate exemption in Mississippi Code section 11-46-9(1)(m) from Burton's false-imprisonment claims arising from his detention at the Raymond Detention Center.

Disposition

reversed_and_remanded