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Slade v. New Horizon Ministries, Inc.

Citations: 785 So. 2d 1077; 2001 Miss. App. LEXIS 88; 2001 WL 216825Docket: No. 1999-CA-00941-COA

Court: Court of Appeals of Mississippi; March 5, 2001; Mississippi; State Appellate Court

Narrative Opinion Summary

This case involves an appeal by Pauline Slade against New Horizon Ministries, Inc. following a summary judgment in favor of New Horizon in a personal injury lawsuit. Slade sustained a broken hip after being knocked down by a participant in a youth program supervised by New Horizon. She contended that the lower court erred in its decision, arguing inadequate supervision. The incident occurred during a recreational activity when some participants were left under the supervision of Mr. Brown. The court affirmed the summary judgment, finding that Slade did not present sufficient evidence of inadequate supervision. The court distinguished this case from Summers v. St. Andrew’s Episcopal School by highlighting that, unlike the Summers case, the supervisor in the current case was actively observing and aware of the incident. The court concluded that the injury was sudden and accidental, with no foreseeable risk apparent to New Horizon, and therefore no issue for a jury regarding supervision adequacy. The appeal costs were assigned to Slade, affirming the circuit court's decision in favor of New Horizon.

Legal Issues Addressed

Adequacy of Supervision in Negligence Claims

Application: The adequacy of supervision by New Horizon was upheld as the supervisor was actively observing the children, contrasting with the precedent cited by the appellant.

Reasoning: The evidence indicates that New Horizon adequately supervised the children, without any indication that the incident was foreseeable or preventable with reasonable precautions.

Proximate Cause in Personal Injury

Application: The court found no proximate cause between the alleged inadequate supervision and Slade's injury, as the incident was sudden and accidental.

Reasoning: Ms. Slade’s injury occurred suddenly and accidentally, with no evidence suggesting that closer supervision would have prevented it.

Reliance on Precedent in Legal Argument

Application: The court distinguished the current case from the precedent cited by Slade, where supervision was inadequate due to absent staff, noting differences in factual circumstances.

Reasoning: Contrarily, in the current case involving Brown, the supervisor was reasonably close, actively observing the children, and aware of the incident.

Standard for Granting Summary Judgment

Application: The court affirmed the summary judgment in favor of New Horizon, indicating that the appellant failed to present sufficient evidence to create a material issue of fact or law.

Reasoning: The court noted that it reviewed the evidence favorably towards Slade but found no material issue of fact or law that warranted overturning the summary judgment.