Case 1:20-cv-00150-HSO-JCG Document 3 Filed 04/30/20 Page 1 of 21

THE UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF MISSISSIPPI
SOUTHERN DIVISION
ESTATE OF JADA BRIGHT; and ON BEHALF
OF THE WRONGFUL DEATH
BENEFICIARIES OF JADA BRIGHT
v.

PLAINTIFF
CAUSE NO. 1:20-CV-150-HSO-JCG

THE ESTATE OF SHELLEY E. ROSE, et al.

DEFENDANTS

JONES COUNTY'S ANSWER TO PLAINTIFF’S COMPLAINT
Comes now Defendant Jones County, Mississippi, by and through counsel, and
in response to Plaintiff’s Complaint would show unto the Court as follows:
FIRST DEFENSE
Plaintiff’s Complaint fails to state a claim upon which any relief may be granted
and, therefore, pursuant to Fed. R. Civ. P. 12(b)(6), the same should be dismissed.
SECOND DEFENSE
Plaintiff’s Complaint fails to state facts against the answering defendant that
would rise to the level of actionable conduct under the laws of the United States, the
Constitution of the United States, the laws of Mississippi, or the Constitution of
Mississippi.
THIRD DEFENSE
Answering defendant specifically asserts and invokes all defenses available to it
as set forth in Fed. R. Civ. P. 12(b)(1) through 12(b)(7) for which a good faith legal
and/or factual basis exists or may exist.

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FOURTH DEFENSE
Insofar as any state law claims are concerned, answering defendant invokes each
and every privilege, immunity, restriction and/or limitation of the Mississippi Tort
Claims Act, Miss. Code Ann. § 11-46-1, et seq., including, but not limited to, the
provisions outlined in Sections 11-46-3, 11-46-5, 11-46-7, 11-46-9, 11-46-11, 11-46-13 and
11-46-15.
FIFTH DEFENSE
Answering defendant denies that it has been guilty of any actionable conduct.
SIXTH DEFENSE
Plaintiff has fraudulently joined the answering defendant in order to defeat
diversity jurisdiction.
SEVENTH DEFENSE
ADMISSIONS AND DENIALS
And now, without waiving any defenses heretofore or hereinafter set forth,
answering defendant responds to the allegations in Plaintiff’s Complaint, paragraph by
paragraph, as follows:
Parties
1.

Answering

defendant

lacks

information

sufficient

to

make

a

determination as to the truth of the allegations of paragraph 1 of Plaintiff’s Complaint
and, as such, denies the same.

2

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2.

Answering

defendant

lacks

information

sufficient

to

make

a

determination as to the truth of the allegations of paragraph 2 of Plaintiff’s Complaint
and, as such, denies the same.
3.

Answering

defendant

lacks

information

sufficient

to

make

a

determination as to the truth of the allegations of paragraph 3 of Plaintiff’s Complaint
and, as such, denies the same.
4.

Answering

defendant

lacks

information

sufficient

to

make

a

determination as to the truth of the allegations of paragraph 4 of Plaintiff’s Complaint,
and, as such, denies the same.
5.

Answering

defendant

lacks

information

sufficient

to

make

a

determination as to the truth of the allegations of paragraph 5 of Plaintiff’s Complaint,
and, as such, denies the same.
6.

Answering

defendant

lacks

information

sufficient

to

make

a

determination as to the truth of the allegations of paragraph 6 of Plaintiff’s Complaint
and, as such, denies the same.
7.

Answering

defendant

lacks

information

sufficient

to

make

a

determination as to the truth of the allegations of paragraph 7 of Plaintiff’s Complaint
and, as such, denies the same.
8.

Answering

defendant

lacks

information

sufficient

to

make

a

determination as to the truth of the allegations of paragraph 8 of Plaintiff’s Complaint
and, as such, denies the same.

3

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9.

Answering defendant admits the allegations of paragraph 9 of Plaintiff’s

Complaint.
10.

Answering defendant admits that Jones County is a political subdivision

of the State of Mississippi and may be served in accordance with the Federal Rules of
Civil Procedure and Mississippi Tort Claims Act, Miss. Code Ann. § 11-46-1 et seq.
Answering defendant denies the remaining allegations of paragraph 10 of Plaintiff’s
Complaint.
11.

Answering defendant admits the allegations of paragraph 11 of Plaintiff’s

Complaint.
12.

Answering defendant admits, upon information and belief, the allegations

of paragraph 12 of Plaintiff’s Complaint.
13.

Answering

defendant

lacks

information

sufficient

to

make

a

determination as to the truth of the allegations of paragraph 13 Plaintiff’s Complaint
and, as such, denies the same.
14.

Answering defendant denies that any of its employees, agents or officials

are liable to Plaintiff. Answering defendant lacks information sufficient to make a
determination as to the truth of the remaining allegations of paragraph 14 Plaintiff’s
Complaint and, as such, denies the same.
Jurisdiction & Venue
15.

Answering defendant denies the allegations of paragraph 15 of Plaintiff’s

Complaint.

4

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16.

Answering defendant denies the allegations of paragraph 16 of Plaintiff’s

Complaint.
Background and Facts
17.

Answering

defendants

lack

information

sufficient

to

make

a

determination as to the truth of the allegations of paragraph 17 of Plaintiff’s Complaint
and, as such denies the same.
Felony DUI 4th Arrest—Lauderdale County
18.

The allegations of paragraph 18 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 18 of
Plaintiff’s Complaint and, as such, denies the same.
19.

The allegations of paragraph 19 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 19 of
Plaintiff’s Complaint and, as such, denies the same.
20.

The allegations of paragraph 20 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 20 of
Plaintiff’s Complaint and, as such, denies the same.
5

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21.

The allegations of paragraph 21 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 21 of
Plaintiff’s Complaint and, as such, denies the same.
22.

The allegations of paragraph 22 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 22 of
Plaintiff’s Complaint and, as such, denies the same.
23.

The allegations of paragraph 23 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 23 of
Plaintiff’s Complaint and, as such, denies the same.
24.

The allegations of paragraph 24 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 24 of
Plaintiff’s Complaint and, as such, denies the same.

6

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25.

The allegations of paragraph 25 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 25 of
Plaintiff’s Complaint and, as such, denies the same.
Arrest - Ellisville Police Department/Jones County
26.

Answering defendant denies the allegations of paragraph 26 of Plaintiff’s

Complaint.
27.

Answering defendant denies the allegations of paragraph 27 of Plaintiff’s

Complaint.
28.

Answering defendant denies the allegations of paragraph 28 of Plaintiff’s

Complaint.
29.

Answering defendant denies the allegations of paragraph 29 of Plaintiff’s

Complaint.
30.

Answering defendant admits that Shelley was arrested by Ellisville Police

Department. Answering defendant denies the remaining allegations of paragraph 30 of
Plaintiff’s Complaint, as stated.
31.

Answering defendant denies the allegations of paragraph 31 of Plaintiff’s

Complaint.
32.

The answering defendant admits that Shelley was transported to Jones

County Jail. Answering defendant denies the remaining allegations of paragraph 32 of
Plaintiff’s Complaint, as stated.
7

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33.

Answering defendant admits that Shelley was held at Jones County Jail

before being released back into the custody of Ellisville Police Department. Answering
defendant denies the remaining allegations of paragraph 33 of Plaintiff’s Complaint, as
stated.
34.

The allegations of paragraph 34 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 34 of
Plaintiff’s Complaint and, as such, denies the same.
Beech Towing
35.

The allegations of paragraph 35 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 35 of
Plaintiff’s Complaint and, as such, denies the same.
36.

The allegations of paragraph 36 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 36 of
Plaintiff’s Complaint and, as such, denies the same.

8

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37.

The allegations of paragraph 37 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 37 of
Plaintiff’s Complaint and, as such, denies the same.
38.

The allegations of paragraph 38 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 38 of
Plaintiff’s Complaint and, as such, denies the same.
39.

The allegations of paragraph 39 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 39 of
Plaintiff’s Complaint and, as such, denies the same.
Thanksgiving Day Accident
40.

Answering defendant lacks information sufficient make a determination

as to the truth of the allegations of paragraph 40 of Plaintiff’s Complaint and, as such,
denies the same.
41.

The allegations of paragraph 41 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
9

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sufficient to make a determination as to the truth of the allegations of paragraph 41 of
Plaintiff’s Complaint and, as such, denies the same.
42.

The allegations of paragraph 42 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 42 of
Plaintiff’s Complaint and, as such, denies the same.
43.

Answering defendant would affirmatively aver that the Exhibit speaks for

itself. Answering defendant denies the remaining allegations of paragraph 43 of
Plaintiff’s Complaint.
44.

Answering defendant admits that Plaintiff decedent died as a result of the

car crash which is the subject of Plaintiff’s Complaint. Answering defendant denies the
remaining allegations of paragraph 44 of Plaintiff’s Complaint.
FIRST CAUSE OF ACTION
Count I – Claims for Negligence against Defendant Shelly
45.

Answering defendant repeats and incorporates by reference each and

every defense, admission, and denial to paragraphs 1-44 hereinabove as if the same
were specifically set out herein.
46.

The allegations of paragraph 46 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information

10

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sufficient to make a determination as to the truth of the allegations of paragraph 46 of
Plaintiff’s Complaint and, as such, denies the same.
47.

The allegations of paragraph 47 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 47 of
Plaintiff’s Complaint and, as such, denies the same.
SECOND CAUSE OF ACTION
Count II - Per Se Violations of Statutory Laws and Duties
48.

Answering defendant repeats and incorporates by reference each and

every defense, admission, and denial to paragraphs 1-47 hereinabove as if the same
were specifically set out herein.
49.

The allegations of paragraph 49 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 49 of
Plaintiff’s Complaint and, as such, denies the same.
50.

The allegations of paragraph 50 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 50 of
Plaintiff’s Complaint and, as such, denies the same.

11

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THIRD CAUSE OF ACTION
Count III – Negligent Entrustment – Rental Car Defendants
51.

Answering defendant repeats and incorporates by reference each and

every defense, admission, and denial to paragraphs 1-50 hereinabove as if the same
were specifically set out herein.
52.

The allegations of paragraph 52 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 52 of
Plaintiff’s Complaint and, as such, denies the same.
53.

The allegations of paragraph 53 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 53 of
Plaintiff’s Complaint and, as such, denies the same.
54.

Answering defendant would aver that the authority cited herein speaks

for itself. Answering defendant denies the allegations of paragraph 54 of Plaintiff’s
Complaint.
55.

The allegations of paragraph 55 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information

12

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sufficient to make a determination as to the truth of the allegations of paragraph 55 of
Plaintiff’s Complaint and, as such, denies the same.
56.

The allegations of paragraph 56 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 56 of
Plaintiff’s Complaint and, as such, denies the same.
FOURTH CAUSE OF ACTION
Count IV – Violation of MTCA Miss. Code Ann. § 11-46-9 Under Mississippi LawLauderdale County
57.

Answering defendant repeats and incorporates by reference each and

every defense, admission, and denial to paragraphs 1-56 hereinabove as if the same
were specifically set out herein.
58.

The allegations of paragraph 58 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 58 of
Plaintiff’s Complaint and, as such, denies the same.
59.

The allegations of paragraph 59 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 59 of
Plaintiff’s Complaint and, as such, denies the same.
13

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60.

The allegations of paragraph 60 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 60 of
Plaintiff’s Complaint and, as such, denies the same.
FIFTH CAUSE OF ACTION
Count V – Violation of MTCA Miss. Code Ann. 11-46-9 Under Mississippi Law – City of
Ellisville and Jones County
61.

Answering defendant repeats and incorporates by reference each and

every defense, admission, and denial to paragraphs 1-60 hereinabove as if the same
were specifically set out herein.
62.

Answering defendant denies the allegations of paragraph 62 of Plaintiff’s

Complaint.
63.

Answering defendant denies the allegations of paragraph 63 of Plaintiff’s

Complaint.
64.

Answering defendant denies the allegations of paragraph 64 of Plaintiff’s

Complaint.
SIXTH CAUSE OF ACTION
Count VI – Negligence – Beech Towing
65.

Answering defendant repeats and incorporates by reference each and

every defense, admission, and denial to paragraphs 1-64 hereinabove as if the same
were specifically set out herein.

14

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66.

The allegations of paragraph 66 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 66 of
Plaintiff’s Complaint and, as such, denies the same.
67.

The allegations of paragraph 67 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 67 of
Plaintiff’s Complaint and, as such, denies the same.
68.

The allegations of paragraph 68 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 68 of
Plaintiff’s Complaint and, as such, denies the same.
69.

The allegations of paragraph 69 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 69 of
Plaintiff’s Complaint and, as such, denies the same.
70.

The allegations of paragraph 70 of Plaintiff’s Complaint concern a

defendant other than answering defendant and, as such, do not require a response. To
15

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the extent a response is deemed necessary, answering defendant lacks information
sufficient to make a determination as to the truth of the allegations of paragraph 70 of
Plaintiff’s Complaint and, as such, denies the same.
Damages
71.

Answering defendant repeats and incorporates by reference each and

every defense, admission, and denial to paragraphs 1-69 hereinabove as if the same
were specifically set out herein.
72.

Answering defendant denies the allegations of paragraph 72 of Plaintiff’s

Complaint and would affirmatively aver that punitive damages are prohibited under
Miss. Code Ann. § 11-46-15.
73.

Answering defendant denies the allegations of paragraph 73 of Plaintiff’s

Complaint.
74.

Answering defendant denies the allegations of paragraph 74 of Plaintiff’s

Complaint, including subparagraphs a-j.
As for the last unnumbered paragraph, which commences, "Therefore, Andre, as
Administrator….," answering defendant denies each and every allegation contained
therein and would affirmatively deny that Plaintiff is not entitled to any recovery of
damages as to Jones County whatsoever.
EIGHTH DEFENSE
Answering defendant is protected by and invokes all the immunities granted to
it by judicial, common law, and statutory sovereign immunity.

16

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NINTH DEFENSE
Answering defendant alleges it has met or exceeded the requirements of law
and due care and that it is guilty of no acts or omissions which either caused or
contributed to the incidents in question.
TENTH DEFENSE
Answering defendant alleges that Plaintiff’s claims are barred by the applicable
statute of limitations, res judicata, abstention, collateral estoppel, laches, waiver,
contributory negligence, accord and satisfaction, lack of standing, release, and/or
estoppel.
ELEVENTH DEFENSE

Plaintiff is not entitled to recover any enhanced, punitive, or exemplary
damages, as provided by Miss. Code Ann. § 11-46-15 insofar as any state court claims
are concerned. Additionally, answering defendant would affirmatively state that the
Plaintiff is not entitled to recover enhanced, punitive, or exemplary damages, the same
being violative of the Fourth, Fifth, Sixth, Eighth, and Fourteenth Amendments of the
Constitution of the United States and Article III, Section 14 of the Constitution of the
State of Mississippi, inclusive of, but not necessarily limited to, the following separate
and several grounds:
(a)

The procedures may result in the award of joint and several judgments

against multiple defendants for different alleged acts of wrongdoing.
(b)

The procedures fail to provide means for awarding separate judgments

against alleged joint tortfeasors.
17

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(c)

The procedures fail to provide a limit on the amount of the award against

the defendants.
(d)

The procedures fail to provide specific standards for the amount of the

award of punitive damages.
(e)

The procedures permit award of punitive damages upon satisfaction of a

standard of proof less than that applicable to the imposition of criminal sanctions.
(f)

The procedures permit multiple awards of punitive damages for the same

alleged act.
(g)

The procedures fail to provide a clear consistent appellant standard of

review of an award for punitive damages.
(h)

The procedures may permit the admission of evidence relative to punitive

damages in the same proceedings during which liability and compensatory damages
are determined.
(i)

The standard of conduct upon which punitive damages are sought is

vague.
TWELFTH DEFENSE
Any allegation in the Complaint not specifically admitted hereinabove, is hereby
denied.
THIRTEENTH DEFENSE
Answering defendant reserves the right to add additional defenses as the same
become known during the course of discovery of this cause.

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And now, having answered the Complaint asserted against it, answering
defendant requests that the same be dismissed and discharged with costs assessed
against the Plaintiff.
DATE:

April 30, 2020.
Respectfully submitted,
JONES COUNTY
BY:

WILLIAM R. ALLEN (MSB #100541)
JESSICA S. MALONE (MSB #102826)
Allen, Allen, Breeland & Allen, PLLC
214 Justice Street
P. O. Box 751
Brookhaven, MS 39602-0751
Tel. 601-833-4361
Fax 601-833-6647
Email: wallen@aabalegal.com
Email: jmalone@aabalegal.com

19

/s/William R. Allen
One of Its Attorneys

 Case 1:20-cv-00150-HSO-JCG Document 3 Filed 04/30/20 Page 20 of 21

CERTIFICATE OF SERVICE
I, the undersigned, of Allen, Allen, Breeland & Allen, PLLC, hereby certify that I
have this day filed the foregoing Jones County’s Answer to Plaintiff’s Complaint with
the Clerk of the Court using the ECF system, which gave notice of the same to the
following:
James G. Wyly, III,Esq.
Scott Ellzey, Esq.
Drury S. Holland, Esq.
Phelps Dunbar, LLP
2602 13th Street, Suite 300
Gulfport, MS 39501
jim.wyly@phelps.com
ellzeys@phelps.com
dru.holland@phelps.com
Attorneys for EAN Holdings, LLC; Enterprise Leasing Company—South
Central, LLC, ELCO Administrative Services Company, and National
Car Rental System, Inc.
and hereby certify that I have mailed a true and correct copy of the same to the
following attorneys of record:
Mary Lee Holmes, Esq.
Marcus A. Mclelland, Esq.
Cory Ferraez, Esq.
Holmes, McLelland & Ferraez, PLLC
601 E. Central Avenue
Petal, MS 39465
marylee@holmeslaw.org
marcus@hmflawfirm.com
cory@hmflawfirm.com
Attorneys for Plaintiff

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Clark Hicks, Jr. Esq.
Hicks Law Firm, PLLC
P.O. Box 18350
Hattiesburg, MS 39404
clark@hicksattorneys.com
Attorney for City of Ellisville
Maison Heidelberg, Esq.
Watson Heidelberg PLLC
2829 Lakeland Drive, Suite 1502
Flowood, MS 39232
mheidelberg@whjpllc.com
Attorney for Beech's Towing and Recovery LLC
This the 30th day of April, 2020.
/s/William R. Allen
OF COUNSEL

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