Spiers v. Oak Grove Credit, LLC, 2020-CA-00827-SCT

CourtUnited States State Supreme Court of Mississippi
Writing for the CourtCHAMBERLIN, JUSTICE, FOR THE COURT
Citation328 So.3d 645
Parties Brittany SPIERS v. OAK GROVE CREDIT, LLC, Columbia Credit, LLC and Pine Belt Credit, LLC
Docket NumberNO. 2020-CA-00827-SCT,2020-CA-00827-SCT
Decision Date18 November 2021

328 So.3d 645

Brittany SPIERS
v.
OAK GROVE CREDIT, LLC, Columbia Credit, LLC and Pine Belt Credit, LLC

NO. 2020-CA-00827-SCT

Supreme Court of Mississippi.

November 18, 2021


ATTORNEY FOR APPELLANT: DANIEL M. WAIDE, Starkville

ATTORNEYS FOR APPELLEES: LINDSAY THOMAS DOWDLE, STACEY MOORE BUCHANAN, Jackson

EN BANC.

CHAMBERLIN, JUSTICE, FOR THE COURT:

¶1. This matter comes before the Court on appeal from an order by the Circuit Court of Lamar County both denying Brittany Spiers leave to amend her complaint and granting the motion to dismiss filed by Oak Grove Credit, LLC (OGC), and other companies, including, Columbia Credit, LLC, Pine Belt Credit, LLC, and "John Does Business 1-5" (collectively, "the Creditor Companies"). We affirm the circuit court's order dismissing the state-law claims, but we reverse the circuit court's order to the extent it denied Spiers leave to amend her complaint. Accordingly, we remand the case for further proceedings.

FACTS AND PROCEDURAL HISTORY

¶2. Spiers worked for OGC, a creditor business located just outside Hattiesburg, Mississippi, until February 2019. At that time, OGC terminated Spiers for reasons Spiers alleged were discriminatory. According to Spiers, OGC terminated her because of her gender and her pregnancy. Specifically, Spiers alleged that her supervisor raised concerns about her pregnancy in regards to work and childcare and even called her pregnancy a "disease." Spiers also alleged that her supervisor declined to hire another person because that person was pregnant.

¶3. On February 7, 2020, Spiers filed her complaint in the circuit court, primarily alleging pregnancy and sex discrimination under Title VII of the Civil Rights Act of 1964. 42 U.S.C. §§ 2000e to 2000e-17 (2012).1 Even though Spiers only worked for OGC, she brought her lawsuit collectively against OGC and the Creditor Companies because she alleged that these companies "constitute an integrated enterprise/joint employer in relation to Spiers as employees from each location are fluid and work for and between the sister companies." Alternatively, Spiers alleged that "the Defendant's actions constitute the torts of negligence, negligent infliction of emotional distress, intentional infliction of emotional distress, termination in violation of public policy, gross negligence, and negligent supervision."

¶4. After Spiers filed her complaint, OGC and the Creditor Companies

328 So.3d 649

filed a notice of removal to the United States District Court for the Southern District of Mississippi. On May 8, 2020, the federal district court issued an order as to Spiers's Title VII claim, finding that Spiers "did not plead sufficient facts for the Court to infer that Defendants meet Title VII's definition of an employer."2 The district court "dismiss[ed] Plaintiff's Title VII claims without prejudice." The district court, however, "declin[ed] to exercise pendent jurisdiction over Plaintiff's remaining state-law claims and remand[ed] the case [back] to the Circuit Court of Lamar County, Mississippi."

¶5. Upon remand to the circuit court, Spiers filed a motion for leave to amend her complaint. In her proposed amended complaint, Spiers added more defendants she deemed constituted "an integrated enterprise" and therefore "qualif[ied] as employers under Title VII and the Pregnancy Discrimination Act." These additional companies include Panther Credit LLC and Personal Finance LLC. Specifically, Spiers alleged the following facts in her proposed amended complaint:

Employees work, train and supervise multiple locations. In addition, [a]ll Defendants share the same management and directors. Upon information and belief, bank accounts and funds are fluid and are moved between companies as different needs arise in different areas. All of the Defendants’ finances, management, and labor relations are centrally controlled.

In making these changes, Spiers attempted to address the factual deficiency of her original complaint that underpinned the federal district court's basis for dismissing her Title VII claim.

¶6. Shortly after Spiers moved to amend, OGC and the Creditor Companies moved to dismiss Spiers's original complaint. In their motion, OGC and the Creditor Companies noted the dismissal of the Title VII claim by the federal district court and argued that the remaining state-law claims must also be dismissed for failure to state a claim. Specifically, OGC and the Creditor Companies argued that (1) Spiers's negligence claims are barred by the exclusivity provisions of the Mississippi Workers’ Compensation Act; (2) Spiers's termination cannot serve as basis for an intentional-infliction-of-emotional-distress claim; and (3) Spiers's wrongful-termination claim cannot succeed because no relevant public-policy exception exists under the employment-at-will doctrine.

¶7. The circuit court held a hearing on both motions. After the hearing, the circuit court ruled from the bench in favor of OGC and the Creditor Companies. The circuit court reasoned that in making its decision it was refusing "to be an activist judge" and that "[t]his matter simply doesn't fit the current law." Then, on July 9, 2020, the circuit court entered its order denying Spiers's motion for leave to amend the complaint and granting OGC and the

328 So.3d 650

Creditor Companies’ motion to dismiss the complaint with prejudice.

¶8. Aggrieved, Spiers appeals.

ISSUES PRESENTED 3

¶9. On appeal, the parties have raised the following issues:

I. Whether the circuit court erred by denying the motion for leave to amend the complaint regarding the Title VII discrimination claim.

II. Whether the circuit court erred by granting the motion to dismiss regarding the state-law claims.

STANDARD OF REVIEW

¶10. "The trial court's denial of a motion to amend a complaint is subject to an abuse of discretion standard of review." Taylor Mach. Works, Inc. v. Great Am. Surplus Lines Ins. Co. , 635 So. 2d 1357, 1362 (Miss. 1994) (citing Broadhead v. Terpening , 611 So. 2d 949, 953 (Miss. 1992) ). Additionally, "[t]his Court reviews de novo a trial court's grant or denial of a motion to dismiss." Johnson v. Rao , 952 So. 2d 151, 154 (Miss. 2007) (citing Harris v. Miss. Valley State Univ. , 873 So. 2d 970, 988 (Miss. 2004) ).

DISCUSSION

I. Whether the circuit court erred by denying the motion for leave to amend the complaint regarding the Title VII discrimination claim.

¶11. The circuit court denied Spiers's motion for leave to amend her complaint. Spiers asserts that the circuit court erred because the proposed amended complaint alleged that OGC and the Creditor Companies qualify as an employer under Title VII. Specifically, Spiers argues that OGC and the Creditor Companies constitute an "integrated enterprise." In turn, OGC and the Creditor Companies argue that Spiers's Title VII complaint amendments cannot survive a motion to dismiss because those amendments are futile—that is, the amendments are conclusory allegations that merely recite the factors used to determine what constitutes an integrated enterprise.4 For the following reasons, we conclude that the circuit court abused its discretion by denying the motion for leave to amend the complaint.

¶12. After the federal district court granted the motion to dismiss Spiers's Title VII claim under Rule 12(b)(6) of the Federal Rules of Civil Procedure, Spiers moved in the circuit court for leave to amend her complaint. Rule 15 of the Mississippi Rules of Civil Procedure governs motions for leave to amend a complaint and states, in part, that "[o]n sustaining a motion to dismiss for failure to state a claim upon which relief can be granted, ... leave to amend shall be granted when justice so requires[.]" M.R.C.P. 15(a) (emphasis added).5 Furthermore, "leave shall be freely given when justice so requires." M.R.C.P. 15(a).

¶13. This Court has noted "that amended pleadings have been liberally permitted throughout Mississippi's legal

328 So.3d 651

history." Webb v. Braswell , 930 So. 2d 387, 393 (Miss. 2006). Even still, however, the rule is not absolute:

In the absence of any apparent or declared reason—such as undue delay, bad faith or dilatory motive on the part of the movant, repeated failure to cure deficiencies by amendments previously allowed, undue prejudice to the opposing party by virtue of allowance of the amendment, futility of the amendment , etc.—the leave sought should, as the rules require, be "freely given."

Id. (emphasis added) (quoting Moeller v. Am. Guar. & Liab. Ins. Co. , 812 So. 2d 953, 962 (Miss. 2002) ).

¶14. OGC and the Creditor Companies argue that the circuit court properly denied the motion for leave to amend the complaint because the proposed amendments were futile. Recently, our Court of Appeals provided a well-stated definition for futility of an amendment. In Griffin v. CitiMortgage, Inc. , the Court of Appeals recognized that "when the proposed ‘amendment would still render the claim futile, the chancellor is well within [her] discretion to deny such request.’ " Griffin v....

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5 practice notes
  • Davis v. Entergy Util. Enters., Civil Action 3:19-CV-848-KHJ-FKB
    • United States
    • United States District Courts. 5th Circuit. Southern District of Mississippi
    • June 24, 2022
    ...“beyond negligence, gross negligence, or recklessness” to pursue a tort claim against an employer. Spiers v. Oak Grove Credit, LLC, 328 So.3d 645, 653 (Miss. 2021) (citation omitted); Miss. Code Ann. §71-3-9. Likewise, Davis does not allege Entergy's conduct was “so outrageous in character,......
  • Holcomb, Dunbar, Watts, Best, Masters & Golmon, P.A. v. 400 S. Lamar Oxford Mad Hatter Partners, LLC, 2019-CT-01702-SCT
    • United States
    • United States State Supreme Court of Mississippi
    • March 17, 2022
    ...a trial court's denial of a motion to amend a pleading, the standard of review is abuse of discretion. Spiers v. Oak Grove Credit , LLC , 328 So. 3d 645, 650 (Miss. 2021) (citing Taylor Mach. Works, Inc. v. Great Am. Surplus Lines Ins. Co. , 635 So. 2d 1357, 1362 (Miss. 1994) ). A de novo s......
  • Prystupa v. Rankin Cnty. Bd. of Supervisors, 2020-CA-01049-COA
    • United States
    • Court of Appeals of Mississippi
    • May 10, 2022
    ...denial of a motion to amend a complaint is subject to an abuse of discretion standard of review." Spiers v. Oak Grove Credit, LLC, 328 So.3d 645, 650 (¶10) (Miss. 2021) (quoting Taylor Mach. Works, Inc. v. Great Am. Surplus Lines Ins. Co., 635 So.2d 1357, 1362 (Miss. 1994)). Discussion I. W......
  • Holcomb, Dunbar, Watts, Best, Masters & Golmon, P.A. v. 400 S. Lamar Oxford Mad Hatter Partners, LLC, 2019-CT-01702-SCT
    • United States
    • United States State Supreme Court of Mississippi
    • March 17, 2022
    ...a trial court's denial of a motion to amend a pleading, the standard of review is abuse of discretion. Spiers v. Oak Grove Credit, LLC, 328 So.3d 645, 650 (Miss. 2021) (citing Taylor Mach. Works, Inc. v. Great Am. Surplus Lines Ins. Co., 635 So.2d 1357, 1362 (Miss. 1994)). A de novo standar......
  • Request a trial to view additional results
5 cases
  • Davis v. Entergy Util. Enters., Civil Action 3:19-CV-848-KHJ-FKB
    • United States
    • United States District Courts. 5th Circuit. Southern District of Mississippi
    • June 24, 2022
    ...“beyond negligence, gross negligence, or recklessness” to pursue a tort claim against an employer. Spiers v. Oak Grove Credit, LLC, 328 So.3d 645, 653 (Miss. 2021) (citation omitted); Miss. Code Ann. §71-3-9. Likewise, Davis does not allege Entergy's conduct was “so outrageous in character,......
  • Holcomb, Dunbar, Watts, Best, Masters & Golmon, P.A. v. 400 S. Lamar Oxford Mad Hatter Partners, LLC, 2019-CT-01702-SCT
    • United States
    • United States State Supreme Court of Mississippi
    • March 17, 2022
    ...a trial court's denial of a motion to amend a pleading, the standard of review is abuse of discretion. Spiers v. Oak Grove Credit , LLC , 328 So. 3d 645, 650 (Miss. 2021) (citing Taylor Mach. Works, Inc. v. Great Am. Surplus Lines Ins. Co. , 635 So. 2d 1357, 1362 (Miss. 1994) ). A de novo s......
  • Prystupa v. Rankin Cnty. Bd. of Supervisors, 2020-CA-01049-COA
    • United States
    • Court of Appeals of Mississippi
    • May 10, 2022
    ...denial of a motion to amend a complaint is subject to an abuse of discretion standard of review." Spiers v. Oak Grove Credit, LLC, 328 So.3d 645, 650 (¶10) (Miss. 2021) (quoting Taylor Mach. Works, Inc. v. Great Am. Surplus Lines Ins. Co., 635 So.2d 1357, 1362 (Miss. 1994)). Discussion I. W......
  • Holcomb, Dunbar, Watts, Best, Masters & Golmon, P.A. v. 400 S. Lamar Oxford Mad Hatter Partners, LLC, 2019-CT-01702-SCT
    • United States
    • United States State Supreme Court of Mississippi
    • March 17, 2022
    ...a trial court's denial of a motion to amend a pleading, the standard of review is abuse of discretion. Spiers v. Oak Grove Credit, LLC, 328 So.3d 645, 650 (Miss. 2021) (citing Taylor Mach. Works, Inc. v. Great Am. Surplus Lines Ins. Co., 635 So.2d 1357, 1362 (Miss. 1994)). A de novo standar......
  • Request a trial to view additional results

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