City of Picayune v. Landry Lewis Germany Architects, P.A.
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The Supreme Court of Mississippi reviewed a case where a city was sued for negligence due to its failure to disclose a juror's potential conflict of interest during a trial. The City of Picayune had originally sued Landry Lewis Germany Architects, alleging defects in an addition to the Picayune City Hall. A juror, Lorenzo Breland, was the son of a Picayune city councilman. The City's representative informed the City's counsel of this relationship, but took no further action. At the end of the trial, the court was informed of this relationship, leading to the dismissal of Breland and a mistrial. Landry Lewis then counter-sued the City for negligence due to its failure to disclose this familial relationship.
The trial court found in favor of Landry Lewis, awarding them $210,000 in damages. However, on appeal, the Supreme Court of Mississippi reversed this decision. The court held that the City of Picayune did not owe a duty of care in tort to Landry Lewis that was breached by its failure to inform the trial court of the potential juror's familial relationship. The court reasoned that trials and voir dire are adversarial processes, and that it is incumbent upon both sides to perform their due diligence in identifying potential conflicts of interest. The court further noted that there were other mechanisms, such as sanctions or bar complaints, to address any perceived misconduct. Therefore, the award of damages for negligence was reversed and rendered.
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