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Case: 25CI1:17-cv-00156-WAG Document #: 8 Filed: 05/10/2017 Page 1 of 12

IN THE CIRCUIT COURT FOR THE FIRST JUDICIAL DISTRICT OF


HINDS COUNTY, MISSISSIPPI

YVETTE MASON-SHERMAN INDIVIDUALLY,


AND ON BEHALF OF THE HEIRS AND
WRONGFUL DEATH BENEFICIARIES OF
CHARLES MCDONALD, JR., DECEASED and
THE ESTATE OF CHARLES MCDONALD, JR.,
DECEASED PLAINTIFFS

V. CIVIL ACTION NO. 2017-156

WAYNE PARISH, JIMMY RATLIFF, AND PERFORMANCE


OIL EQUIPMENT, INC. DEFENDANTS

DEFENDANT, WAYNE PARISHS,


ANSWER AND AFFIRMATIVE DEFENSES TO
PLAINTIFFS FIRST AMENDED COMPLAINT

COMES NOW, Defendant Wayne Parish by and through its undersigned counsel, and

responds to Plaintiffs First Amended Complaint as follows:

FIRST DEFENSE

The Complaint fails to state a claim or cause of action upon which relief can be granted

against this Defendant.

SECOND DEFENSE

This Defendant incorporates each and every defense available to it as set forth in Rule

12(b)(1)(7) of the Mississippi Rules of Civil Procedure (M.R.C.P.) pursuant to which this

Defendant demands that the action filed herein against it be dismissed with prejudice.

THIRD DEFENSE

This Defendant generally denies all of the averments contained in the Complaint, and

each paragraph and subparagraph thereof, except such designated averments, paragraphs or

subparagraphs, as are expressly set forth to the contrary more fully herein below pursuant to Rule

8(b) of the Mississippi Rules of Civil Procedure.


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FOURTH DEFENSE

Should this Defendant be held liable to the Plaintiff, this Defendant is entitled to

contribution and apportionment of liability pursuant to Miss. Code Ann. '85-5-7. It would be

unconstitutional to hold this Defendant responsible for the criminal acts in question.

FIFTH DEFENSE

Defendant affirmatively pleads that some or all of the losses allegedly suffered by the

Plaintiff, and which are the subject of Plaintiffs Complaint, were cause entirely by the actions of

the Decedent, and therefore, the Plaintiff is not legally entitled to recover damages from this

Defendant

SIXTH DEFENSE

Defendant affirmatively pleads self-defense.

SEVENTH DEFENSE

Defendant affirmatively pleads Miss. Code. Ann. 97-3-15(3), also known as the Castle

Doctrine.

EIGHT DEFENSE

Defendant asserts that the Decedent was a trespasser and he did nothing willfully or

wantonly to injure the Decedent.

NINTH DEFENSE

Defendant asserts that the subject premises was reasonably safe at the time of the subject

incident

TENTH DEFENSE

Defendant asserts that the sole proximate cause of the Decedents injuries and damages

was the criminal conduct of the Decedent.

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ELEVENTH DEFENSE

The imposition of exemplary or punitive damages in this case would deprive this

Defendant of property without due process of law and would deny to this Defendant the equal

protection of the laws in violation of the Fourteenth Amendment of the United States

Constitution and in violation of Article 3, Section 14 and Article 3, Section 24 of the

Constitution of the State of Mississippi. Therefore, these claims should be dismissed.

TWELFTH DEFENSE

The imposition of exemplary or punitive damages in this matter would constitute

imposition of an excessive fine in violation of Amendment VIII of the United States

Constitution, prohibiting excessive fines, cruel and unusual punishments and Article 3, Section

28 of the Constitution of the State of Mississippi, prohibiting excessive fines. Therefore, these

claims should be dismissed.

THIRTEENTH DEFENSE

The imposition of exemplary or punitive damages in this matter violate the provisions of

the Contract Clause of Article I, Section X, Clause 1 of the United States Constitution,

prohibiting any law which impairs the obligation of contracts and of Article 3, Section 16 of the

Constitution of the State of Mississippi, prohibiting laws which impair the obligation of

contracts. Therefore, these claims should be dismissed.

FOURTEENTH DEFENSE

This Defendant affirmatively pleads that he is not responsible for any injuries and

damages alleged by the Plaintiff which are pre-existing conditions which preceded this incident.

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FIFTHEENTH DEFENSE

This Defendant reserves the right to affirmatively plead any and all other defenses and

affirmative defenses available to it which may become applicable through discovery and during

the trial of this cause.

SIXTEENTH DEFENSE

The facts not having been fully developed, this Defendant adopts the following

affirmative defenses: Accord and satisfaction, arbitration and award, assumption of risk,

contributory negligence, discharge in bankruptcy, duress, estoppel, failure of consideration,

fraud, illegality, injury by fellow servant, laches, license, payment, release, res judicata, statute

of frauds, statute of limitations, waiver, and any other matter constituting an avoidance or

affirmative defense as may be shown by the facts in this cause, including, but not limited to, the

right to claim indemnity from any or all of the other defendants and to file a cross-claim or other

pleading to assert said claim.

SEVENTEENTH DEFENSE

This Defendant avers that any award of punitive damages to the Plaintiff in this case

would be a violation of the constitutional rights and safeguards provided to Defendant under the

Constitution of the State of Mississippi and the Constitution of the United States of America

including, without limitations, that there are no constraining limitations placed on a jurys

discretion in considering the imposition or amount of punitive damages. There are no

meaningful trial court and appellate review mechanisms to constitutionally confirm any punitive

damages award, and imposition would allow a verdict obtained by passion and prejudice.

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EIGHTEENTH DEFENSE

Imposition of punitive damages in this case would constitute a violation of this

Defendants constitutional rights under the Fourth, Fifth, Sixth, Eighth and Fourteenth

Amendments to the Constitution of the United States of America.

NINTEENTH DEFENSE

Any award of punitive damages in this case would violate the constitutional rights and

safeguards provided to this Defendant under the due process clause of the Fourteenth

Amendment and/or Fifth Amendment to the Constitution of the United States of America and/or

under the due process clause of Article III, Section 14 of the Constitution of the State of

Mississippi and that punitive damages and any method by which they might be assessed are

unconstitutionally vague and not rationally related to legitimate government interest. If

consideration of punitive damages is to be allowed, then the standard for proving the same, as

provided in Miss. Code Ann. Sections 11-1-63 and 11-1-65 (Supp. 1993), must be by clear and

convincing evidence.

TWENTIETH DEFENSE

The procedure and/or standards governing imposition of punitive damages are

impermissibly vague, arbitrary, improper and/or violates the due process clause of the Fourteenth

Amendment and/or the Fifth Amendment of the Constitution of the United States of America

and/or Article III, Section 14 of the Constitution of the State of Mississippi.

TWENTY-FIRST DEFENSE

Any award of punitive damages in this Case would violate the procedural and/or

substantive safeguards provided to this Defendant under the Fifth, Sixth, Eighth and/or

Fourteenth Amendments to the Constitution of the United States and/or under Article III, Section

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14 and 26 of the Constitution of the State of Mississippi, and that punitive damages are penal in

nature and, consequently, this Defendant is entitled to the same procedural and substantive

safeguards afforded to criminal defendants.

TWENTY-SECOND DEFENSE

It violates the rights and safeguards guaranteed by the Constitution of the United States of

America and/or the Constitution of the State of Mississippi to impose punitive damages against

this Defendant. To do so would be penal in nature and require a burden of proof which is less

than the beyond a reasonable doubt burden of proof required in criminal cases in this State, and

less than a unanimous jury verdict.

TWENTY-THIRD DEFENSE

This Defendant avers that any award of punitive damages to the Plaintiff in this case

would violate the Eighth Amendment to the Constitution of the United States and/or Article III,

Section 28 of the Constitution of the State of Mississippi in that said punitive damages would be

an imposition of an excessive fine.

TWENTY-FOURTH DEFENSE

It will be unconstitutional to award any punitive damages as such would violate the Fifth

and Fourteenth Amendments to the United State Constitution and Article III, Section 14 of the

Mississippi State Constitution in that:

1. Said damages are intended to punish and deter this Defendant and thus this

proceeding is essentially criminal in nature;

2. This Defendant is being compelled to be a witness against himself in a proceeding

essentially and effectively criminal in nature, in violation of its right to due

process;

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3. The Plaintiffs burden of proof to establish punitive damages in this proceeding,

effectively criminal in nature, is less than the burden of proof required in other

criminal proceedings, and thus violates this Defendants right to due process;

4. That inasmuch as this proceeding is essentially and effectively criminal in nature,

this Defendant is being denied the requirements of notice of the elements of the

offense, and the law and authorities authorizing punitive damages are so vague

and ambiguous they are in violation of the due process clause of the Fifth

Amendment and/or the Fourteenth Amendment of the Constitution of the United

States and also in violation of Article III, Section 14 of the Constitution of the

State of Mississippi.

TWENTY-FIFTH DEFENSE

This Defendant avers that any award of punitive damages to the Plaintiff in this case

would be in violation of the constitutional rights and safeguards provided to this Defendant,

under the Constitution of the State of Mississippi and the Constitution of the United States of

America including, without limitation, that there are no constraining limitations placed on a

jurys discretion in considering the imposition or amount of punitive damages, there are no

meaningful trial court and appellate review mechanisms to constitutionally confirm any punitive

damage award, imposition would allow a verdict tainted by passion and prejudice, and Plaintiff

impermissibly seeks a punitive damage award that bears an unconstitutional relationship to the

alleged actual amount in question.

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TWENTY-SIXTH DEFENSE

With respect to each and every cause of action, Plaintiff is not entitled to recover because

of any superseding and/or intervening acts and/or omissions of persons or entities other than

Defendants.

TWENTY-SEVENTH DEFENSE

If Plaintiff has made or does make settlement with any person or party whatsoever for all

or any part of the damages claimed herein, then this Defendant is entitled to full or other credit

for the amount of such settlement for the damages otherwise recoverable against this Defendant

herein, with said settlement credit to be given in accord with the procedures and statutes so

provided.

TWENTY-EIGHT DEFENSE

The Complaint must be dismissed pursuant to Miss. R. Civ. P. 12(b)(6) and or 12(e), or,

in the alternative, Plaintiff must replead the Complaint in order to satisfy the requirements of

Miss. R. Civ. P. 8, 9 and 11. The recent Mississippi Supreme Court decision in Harolds Auto

Parts, Inc. et al v. Flower Mangialardi, et al No. 2004-IA-01308-SCT (Miss., August 26, 2004)

establishes that, to satisfy Rules 8, 9 and 11, Plaintiffs must plead specific facts and legal

conclusions that provide Defendants fair notice of each claim made against them and the grounds

thereof. The Complaint fails to meet this standard and must be dismissed, or Plaintiff must be

required to replead it.

TWENTY-NINTH DEFENSE

Plaintiff cannot recover against Defendant pursuant to any theory with regard to

bystander liability.

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THIRTIETH

Plaintiff cannot recover against Defendant pursuant to any theory with regard to premises

liability.

THIRTY-FIRST

Defendant committed no act of negligence, gross negligence or any other wrongdoing

that caused or contributed to Plaintiffs alleged damages.

ANSWER

Defendants responds to Plaintiffs Complaint paragraph by paragraph as follows:

PARTIES

1. Defendant lacks knowledge or information sufficient to form a belief as to the truth or

veracity of the allegations contained in Paragraph 1 of the Complaint. Therefore, the allegations

are denied.

2. Defendant admits the allegations contained in paragraph 2 of the Complaint.

3. Defendant admits the allegations contained in paragraph 3 of the Complaint.

4. Defendant admits the allegations contained in paragraph 4 of the Complaint.

JURISDICTION AND VENUE

5. Defendant admits that this court has jurisdiction over the parties and the subject matter

of this action. However, Defendant denies the remaining allegations contained in paragraph 5.

6. Defendant admits the allegation contained in paragraph 2 of the Complaint.

STATEMENT OF FACTS

7. Defendant lacks knowledge or information sufficient to form a belief as to the truth or

veracity of the allegations contained in Paragraph 7 of the Complaint. Therefore, the allegations

are denied.

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8. Defendant admits the allegations contained in paragraph 8 of the Complaint.

9. Defendant lacks knowledge or information sufficient to form a belief as to the truth or

veracity of the allegations contained in Paragraph 9 of the Complaint. Therefore, the allegations

are denied.

10. Defendant lacks knowledge or information sufficient to form a belief as to the truth or

veracity of the allegations contained in first sentence of Paragraph 10 of the Complaint.

Therefore, the allegations are denied. The remaining allegations of Paragraph 10 are denied

11. Defendant lacks knowledge or information sufficient to form a belief as to the truth or

veracity of the allegations contained in Paragraph 11 of the Complaint. Therefore, the

allegations are denied.

12. Defendant admits the allegations contained in Paragraph 12 of the Complaint.

13. Defendant denies the allegations contained in Paragraph 13 of the Complaint.

14. Defendant denies the allegations contained in Paragraph 13 of the Complaint.

15. Defendant denies the allegations contained in Paragraph 13 of the Complaint.

16. Defendant denies the allegations contained in Paragraph 13 of the Complaint.

17. Defendant denies the allegations contained in Paragraph 13 of the Complaint.

18. As the allegations described in Paragraph 18 of the Complaint are directed towards

another Defendant, Defendant reserves response to this allegations. To the extent a response is

required, the allegations are denied.

19. Defendant denies the allegations contained in Paragraph 19 of the Complaint.

CAUSES OF ACTION

20. Defendant denies the allegations contained in Paragraph 20 of the Complaint (including

but not limited to subparagraphs: a., b., c., d., and e) of the Complaint.

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21. Defendant denies the allegations contained in Paragraph 21 of the Complaint.

DAMAGES

22. Defendant denies the allegations contained in Paragraph 22 of the Complaint.

23. Defendant denies the allegations contained in Paragraph 23 of the Complaint.

24. Defendant denies the allegations contained in Paragraph 24 of the Complaint.

Defendant denies the allegations of the next unnumbered paragraph of the Plaintiffs

Complaint which begins with WHEREFORE, PREMISES CONSIDERED, and deny that

Plaintiffs are entitled to the relief requested.

AND NOW having fully answered the allegations of Plaintiffs Complaint, Defendant,

Wayne Parish, requests that this Court grant the following relief:

a) A judgment in favor of Defendant dismissing all of Plaintiffs claims hereunder with

prejudice;

b) An award of all court costs and legal expenses including, but not limited to, attorneys

fees incurred in this matter; and,

c) That judgment be rendered for Defendant for such other relief as may be deemed by the

Court to be just and proper in the premises or other such relief that this Court may provide.

RESPECTFULLY SUBMITTED this the 10th day of May, 2017.

WAYNE PARISH

BY: /s/Robert L. Gibbs


ROBERT L. GIBBS

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OF COUNSEL:

Robert L. Gibbs, MSB No. 99692


Tujuana S. McGee, MSB No. 104263
Gibbs Travis PLLC
1400 Meadowbrook Road, Suite 100
Jackson, Mississippi 39211
Telephone: (601) 487-2640
Facsimile: (601)366-4295
Email: rgibbs@gibbstravis.com
Email: tmcgee@gibbstravis.com

CERTIFICATE OF SERVICE

The undersigned hereby certifies that a true copy of the foregoing was duly served upon

all known counsel of record, this the 10th day of May, 2017, and upon all parties registered with

the Courts electronic filing system by operation of the Courts MEC system.

/s/ Robert L. Gibbs


ROBERT L. GIBBS

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IN THE CIRCUIT COURT OF HINDS COUNTY, MISSISSIPPI


FIRST JUDICIAL DISTRICT

YVETTE MASON-SHERMAN, INDIVIDUALLY,


AND ON BEHALF OF THE HEIRS AND
WRONGFUL DEATH BENEFICIARIES OF
CHARLES MCDONALD, JR., DECEASED, and
THE ESTATE OF CHARLES MCDONALD, JR.,
DECEASED PLAINTIFFS

V. CAUSE NO.: 2017-156

WAYNE PARISH, JIMMY RATLIFF, AND PERFORMANCE


OIL EQUIPMENT, INC. DEFENDANTS

FIRST AMENDED COMPLAINT


(Jury Trial Demanded)

COME NOW, the Plaintiffs, Yvette Mason-Sherman, Individually, and as

Administrator of the Estate of Charles McDonald, Jr., and On Behalf of the Heirs and

Wrongful Death Beneficiaries of Charles McDonald, Jr., Deceased, and The Estate of

Charles McDonald, Jr., Deceased (hereinafter Plaintiffs), by and through their

attorneys of record, and file this, their FIRST AMENDED COMPLAINT, and would

allege the following:

PARTIES

1. Plaintiff Yvette Mason-Sherman is an adult resident citizen of Mississippi,

residing in Hinds County, Mississippi. She brings suit on behalf of the wrongful

death beneficiaries of Charles McDonald, Jr., (Decedent), for the negligent

actions that caused his death.

2. Defendant Wayne Parish (Defendant Parish) is an adult resident citizen of

Mississippi, and can be served with process at his place of employment located

at 920 E. McDowell Road, Jackson, MS 39204.

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3. Defendant Jimmy Ratliff (Defendant Ratliff), is an adult resident citizen of

Mississippi, and can be served with process at 137 Delvin Springs Drive,

Madison, MS 39110.

4. Defendant Performance Oil Equipment, Inc. (Defendant POE) is a domestic

corporation qualified to do business within the State of Mississippi, and may be

served with process upon its registered agent, Jimmy Ratcliff, located at 920

East McDowell Road, Jackson, MS 39204.

JURISDICTION AND VENUE

5. The Circuit Court of the First Judicial District of Hinds County, Mississippi has

exclusive jurisdiction of the parties and the subject matter of this action. No other

Court has original jurisdiction of this matter. This civil action arises out of the

negligent acts and/or omissions of the Defendants committed in the State of

Mississippi against a resident of the State of Mississippi. This Court has

jurisdiction over this claim because this is an action at law seeking monetary

damages within the jurisdiction of the Circuit Court.

6. Venue is proper in this court pursuant to Miss. Code Ann. 11-11-3, since each

of the parties can be found there.

STATEMENT OF FACTS

7. At all pertinent times hereto, Defendant Ratliff was the President of POE.

Defendant Parish was the Vice-President of POE.

8. At all pertinent times hereto, the Decedent was a trespasser at POE.

9. On or about July 21, 2016, Plaintiff was transporting Decedent to the Henley-

Young Juvenile Justice Center, which is next door to Defendant POE.

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10. Upon arrival at the juvenile justice center, Decedent fled Plaintiffs vehicle and

ran to POE. Defendant Parish exited the store with a gun and aggressively

approached Decedent in the parking lot. Subsequently, an altercation began

between Decedent and Defendant Parish. Decedent was shot by Defendant

Parish. Decedent suffered multiple gunshot wounds to the upper torso.

11. Decedent was transported to the University of Mississippi Medical Center

Jackson where he was pronounced dead shortly after arrival. Decedent expired

on July 21, 2016.

12. At all times pertinent Decedent was a trespasser of the Defendants. As a

trespasser, the Defendants owed a duty to Decedent to refrain from causing

willful and wanton injury.

13. As a direct and proximate cause of the Defendants failure to maintain the

premises in a reasonably safe manner, Decedent was willfully and wantonly

injured. He experienced excruciating pain and expired on July 21, 2016. Plaintiff

experienced and continues to experience excruciating pain and suffering as a

result of the death of Decedent.

14. Defendants failed to provide adequate security which would have deterred

Defendant Parish from exiting the store, in possession of a firearm, posing and

ultimately causing harm and the death of Decedent.

15. Defendants, at all times relevant hereto, failed to prevent wanton and willful injury

to Decedent on the premises.

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16. Defendants owed a duty to Decedent to prevent willful and wanton injury on the

premises and to hire adequately trained employees and agents specifically

adequate training in firearms and the use of deadly force.

17. Defendants were the owners, agents, or principals of each other or in a joint

venture and were in control of the premises in some form.

18. Defendants, Jimmy Ratliff and Performance Oil Equipment, Inc., negligently

hired, trained, and retained Defendant Parish.

19. Defendants negligently entrusted a gun with Defendant Parish to carry and

secure the premises.

CAUSES OF ACTION

20. The following actions and/or inactions of the Defendants and its agents

constituted negligence and/or breach of duties owing from the Defendants to the

Decedent:

a. Failure to refrain from willfully or wantonly injuring the Decedent;

b. Failure to warn of a known and serious hidden danger;

c. Failure to hire adequately trained employees and agents;

d. Intentional and negligently inflicting mental and emotional distress; and

e. For other acts, inactions, failures, omissions, negligent, intentional and

grossly negligent conduct to be shown at trial.

21. The foregoing actions and/or inactions of the Defendants and their agents

constituted gross negligence, to-wit; they willfully and wantonly injured Decedent

by consciously disregarding a known and hidden danger.

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DAMAGES

22. As a direct and proximate result of the concurrent, intentional, willful, unlawful,

reckless, wanton, grossly negligent and/or unreasonably dangerous actions of

the Defendants, the Decedent expired on July 21, 2016, and on account of the

same, the Plaintiff is entitled to recover compensatory and punitive damages.

Also, Plaintiff is entitled to recover and hereby request from the Defendants,

jointly and severally, all additional damages which she is entitled to recover as a

result of the death of Decedent on July 21, 2016.

23. Further, as a direct and proximate result of the concurrent, intentional, willful,

unlawful, reckless, wanton, grossly negligent and/or unreasonably dangerous

actions of the Defendants, the Plaintiff suffered and experienced excruciating

pain, suffering, mental anguish, agony, loss of life, loss of society, and funeral

expenses. On account of the same, the Plaintiff is entitled to recover damages.

24. Defendants negligent acts and omissions were grossly negligent and/or in

reckless disregard for the Decedent, Plaintiff, and the publics rights and safety.

Therefore, Plaintiff is entitled to an award of punitive damages against the

Defendants.

WHEREFORE, PREMISES CONSIDERED, Plaintiff sues and demands a

judgment of and from the Defendants for actual and punitive damages together with all

costs of this action, inclusive of pre-judgment and post-judgment interest.

Respectfully submitted, this the 17TH day of March, 2017.

YVETTE MASON-SHERMAN, ET AL., PLAINTIFFS

BY: /s/ Carlos E. Moore


Carlos E. Moore, MSB# 100685

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Michael S. Carr, MSB# 102138


Attorneys for Plaintiffs

OF COUNSEL:

TUCKER MOORE LAW GROUP, LLP.


306 Branscome Drive
P. O. Box 1487
Grenada, MS 38902-1487
662-227-9940 phone
662-227-9941 fax
Email: carlos@carlosmoorelaw.com

OF COUNSEL:

CARR & CALDERN, PLLC


303 Cotton Row
P.O. Box 1818
Cleveland, MS, 38732
Phone: (662) 545-4445
Fax: 1 (662) 796-3689
Email: mcarr@carrcalderon.com

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