Mississippi Transportation Commission v. AdamsAnnotate this Case
In an interlocutory appeal, defendants the Mississippi Transportation Commission (“MTC”) and the Mississippi Department of Transportation (“MDOT”) moved for summary judgment to dismiss the case against them on immunity grounds under the Mississippi Tort Claims Act (“MTCA”). Christopher Adams died from injuries he sustained when his motorcycle wrecked on Interstate 10 in Jackson County. After traveling north on Interstate 110 in Harrison County, Adams merged onto an eastbound lane of I-10, where he entered a construction zone. According to the complaint, Adams inadvertently drove into a closed lane and then, when he tried to navigate back into an open lane, his motorcycle hit an uneven surface between lanes and “rotated.” Adams was thrown from his motorcycle and into traffic, where two other vehicles hit him, causing injuries from which he later died. Adams' estate raised a number of claims against defendants all sounding in negligence and relating to the condition of the road, failure to place proper warnings, and creating hazardous driving conditions. The trial judge rejected the defendants’ argument that, notwithstanding certain narrower regulations requiring specific actions, they were immune from liability because the broader function of traffic-control-device placement was discretionary. Finding no reversible error in the trial court's judgment, the Supreme Court affirmed the denial of immunity.