exhaustion doctrine (Mississippi) · Go Syfert
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exhaustion doctrine in Mississippi

14 Mississippi opinions name it 2 courts 1963–2026 6 in the last five years

The cases below were cited by Mississippi courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
Donald v. Amoco Production Co.green
miss · 1999 · cited in 3 Mississippi opinions naming this issue, 2021–2024
2 sentences

2024Co., 735 So. 2d 161, 176 (Miss. 1999)).

2022Co., 735 So. 2d 161, 176 (Miss. 1999)). ¶12.

23
Klammer v. Lower Sioux Convenience Storegreen
minnctapp · 1995 · cited in 2 Mississippi opinions naming this issue, 1996–1997
2 sentences

1997In Klammer v. Lower Sioux Convenience Store, 535 N.W.2d 379, 381 (Minn. App. 1995), the Minnesota Court of Appeals, relying on LaPlante , stated "The exhaustion requirement is a matter of comity; it is not a jurisdictional prerequisite." Moreover, in LaPlante , the Supreme Court noted, "Tribal courts play a vital role in tribal self-government and the federal government has consistently encouraged their development." 480 U.S. at 14-15 , 107 S.Ct. at 975-76 .

1996In Klammer v. Lower Sioux Convenience Store, 535 N.W. 2d 379, 381 (Minn. App. 1995), the Minnesota Court of Appeals, relying on LaPlante, stated"The exhaustion requirement is a matter of comity; it is not a jurisdictional prerequisite." Moreover, in LaPlante, the Supreme Court noted, "Tribal courts play a vital role in tribal self-government and the federal government has consistently encouraged their development." 480 U.S. at 14-15 .

22
MISS. DEPT. OF ENVIRON. QUAL. v. Weemsgreen
miss · 1995 · cited in 3 Mississippi opinions naming this issue, 1997–2021
2 sentences

2001Quality v. Weems, 653 So.2d 266 (Miss.1995), sets out the factors which should be considered in determining whether to apply the exhaustion doctrine.

1997Quality v. Weems, 653 So. 2d 266 (Miss. 1995), sets out the factors which should be considered in determining whether to apply the exhaustion doctrine.

13
Campbell Sixty-Six Express, Inc. v. J. & G. Express, Inc.green
miss · 1962 · cited in 2 Mississippi opinions naming this issue, 2015–2026
2 sentences

2026“The [Supreme Court] has set out several factors that weigh against an exhaustion requirement: ‘the pursuit of the administrative remedy would result in irreparable harm; the agency clearly lacks jurisdiction; the agency’s position is clearly illegal; the dispositive question is one of law; exhaustion would be futile; and comparatively, the action can be disposed of with less expense and more efficiently in the judicial arena.’” Id. (quoting Hawkins, 781 So. 2d at 906 (¶31)). ¶14.

2015Exp., Inc., 244 Miss. 427, 440 , 141 So.2d 720, 726 (1962)). ¶ 75.

12
PERS OF MS v. Hawkinsgreen
miss · 2001 · cited in 2 Mississippi opinions naming this issue, 2015–2026
2 sentences

2026“The [Supreme Court] has set out several factors that weigh against an exhaustion requirement: ‘the pursuit of the administrative remedy would result in irreparable harm; the agency clearly lacks jurisdiction; the agency’s position is clearly illegal; the dispositive question is one of law; exhaustion would be futile; and comparatively, the action can be disposed of with less expense and more efficiently in the judicial arena.’” Id. (quoting Hawkins, 781 So. 2d at 906 (¶31)). ¶14.

2026Bright Beginnings argues that an exhaustion requirement is not appropriate in this case because its appeal presents a “question of law” that does not require any specialized “agency expertise.” Hawkins, 781 So. 2d at 907 (¶¶33-34).

12
Vince Hardaway v. Howard Industries, Inc.green
missctapp · 2016 · cited in 1 Mississippi opinions naming this issue, 2021–2021
1 sentence

2021In Hardaway, we held that a plaintiff “must obtain a final judgment from the Commission that he is entitled to benefits . . . before instituting an action for the alleged bad faith denial of those benefits.” Hardaway, 211 So. 3d at 722 (¶16).

11
Bailey v. Al-Meftygreen
miss · 2001 · cited in 1 Mississippi opinions naming this issue, 2008–2008
1 sentence

2008"The primary rule of construction is to ascertain the intent of the legislature from the statute as a whole and from the language used therein." Bailey v. Al-Mefty, 807 So.2d 1203, 1206 (Miss.2001) (quoting Clark v. State ex rel.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Mississippi. Read the followed side critically anyway.

Also cited on this issue (7)

CaseCitedYears
Kaul v. Wahquahboshkuk green
ksd · 1993
2 sentences

1997In Kaul v. Wahquahboshkuk, 838 F. Supp. 515 (D.Kan. 1993), that Court considering the exhaustion of tribal remedies, stated, "The federal courts created this rule `because of Congress' strong interest in promoting tribal sovereignty, including the development of tribal courts.'" Id. at 517 .

1997In Kaul v. Wahquahboshkuk, 838 F. Supp. 515 (D.Kan. 1993), that Court considering the exhaustion of tribal remedies, stated, "The federal courts created this rule `because of Congress' strong interest in promoting tribal sovereignty, including the development of tribal courts.'" Id. at 517 .

21996–1997
Iowa Mutual Insurance v. LaPlante green
scotus · 1987
2 sentences

1997In Klammer v. Lower Sioux Convenience Store, 535 N.W.2d 379, 381 (Minn. App. 1995), the Minnesota Court of Appeals, relying on LaPlante , stated "The exhaustion requirement is a matter of comity; it is not a jurisdictional prerequisite." Moreover, in LaPlante , the Supreme Court noted, "Tribal courts play a vital role in tribal self-government and the federal government has consistently encouraged their development." 480 U.S. at 14-15 , 107 S.Ct. at 975-76 .

1997In Klammer v. Lower Sioux Convenience Store, 535 N.W.2d 379, 381 (Minn. App. 1995), the Minnesota Court of Appeals, relying on LaPlante , stated "The exhaustion requirement is a matter of comity; it is not a jurisdictional prerequisite." Moreover, in LaPlante , the Supreme Court noted, "Tribal courts play a vital role in tribal self-government and the federal government has consistently encouraged their development." 480 U.S. at 14-15 , 107 S.Ct. at 975-76 .

21996–1997
Chevron USA, Inc. v. Smith green
miss · 2002
2 sentences

2024Under the exhaustion doctrine, “[w]here an administrative agency regulates certain activity, an aggrieved party must first seek relief from the administrative agency before seeking relief from the trial courts.” Pace, 353 So. 3d at 433 (¶ 11) (internal quotation marks omitted) (quoting Chevron U.S.A., Inc. v. Smith, 844 So. 2d 1145 (Miss. 2002)).

2024Although “where no adequate administrative remedy is provided, the exhaustion doctrine is not applicable.” Id. (internal quotation marks omitted) (quoting Petro Harvester Oil & Gas Co., LLC v. Baucum, 323 So. 3d 1041 , 1046 (Miss. 2021)). 7 ¶15.

12024–2024
State v. Beebe green
miss · 1996
1 sentence

2021“However, where no adequate administrative remedy is provided, the exhaustion doctrine is not applicable.” Id. (citing Miss.

12021–2021
Gauze v. Reed green
wva · 2006
1 sentence

2008Further, holding a solvent primary insurer liable for providing first-dollar coverage, even though its policy contains an other-insurance clause, cannot be deemed to be unfair because such an insurer "has contracted for and received a premium for a risk as though it were a primary insurer...." Gauze, 633 S.E.2d at 333 .

12008–2008
Marie Von Hoffburg v. Clifford Alexander, Etc. green
ca5 · 1980
2 sentences

2005The court rejected Von Hoffburg's argument that her request for money damages was sufficient to defeat the exhaustion requirement, stating that the "inclusion of a monetary damage claim should not deprive the Army of a chance to review its own rules and regulations prior to judicial intervention," and "[w]here the relief claimed is the only factor that militates against the application of the exhaustion requirement, the complaint should be carefully scrutinized to ensure that the claim for relief was not asserted for the sole purpose of avoiding the exhaustion rule." Id. at 641 .

2005The court rejected Von Hoffburg's argument that her request for money damages was sufficient to defeat the exhaustion requirement, stating that the "inclusion of a monetary damage claim should not deprive the Army of a chance to review its own rules and regulations prior to judicial intervention," and "[w]here the relief claimed is the only factor that militates against the application of the exhaustion requirement, the complaint should be carefully scrutinized to ensure that the claim for relief was not asserted for the sole purpose of avoiding the exhaustion rule." Id. at 641 .

12005–2005
Highland Village Co. v. City of Jackson green
miss · 1962
2 sentences

1963For example, the exhaustion doctrine was applied to an individual property owner in Highland Village Co. v. City of Jackson, 243 Miss. 34 , 137 So. 2d 549 (1962).

1963For example, the exhaustion doctrine was applied to an individual property owner in Highland Village Co. v. City of Jackson, 243 Miss. 34 , 137 So. 2d 549 (1962).

11963–1963

Statutes the citing opinions construe

MS § Miss. Code Ann. § 53-1-17 (3) MS § Miss. Code Ann. § 53-1-43 (3) MS § Miss. Code Ann. § 53-1-47 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 418 (1897–2026) CT 286 (1979–2026) TX 203 (1973–2026) IL 189 (1963–2026) NY 151 (1974–2026) IN 98 (1979–2026) PA 93 (1954–2026) WA 71 (1984–2026) IA 70 (1972–2026) MD 61 (1980–2023) MA 52 (1976–2026) NJ 51 (1962–2024) WI 44 (1974–2026) FL 43 (1976–2025) MI 38 (1968–2026) AZ 37 (1963–2023) OH 36 (1975–2025) GA 36 (1980–2026) CO 36 (1974–2026) KS 36 (1974–2026) OR 35 (1974–2026) ID 29 (1978–2026) NV 28 (1992–2025) DC 27 (1985–2017) NM 27 (1966–2025) RI 27 (1966–2026) AK 27 (1981–2025) UT 24 (1992–2024) MT 24 (1981–2025) MO 23 (1957–2021) VT 21 (1986–2025) HI 20 (1987–2025) LA 19 (1989–2024) NC 18 (1991–2022) OK 18 (1977–2018) WY 17 (1982–2025) AL 16 (1980–2012) TN 16 (1995–2025) MN 15 (1981–2012) ME 15 (1984–2024) MS 14 (1963–2026) NE 14 (1998–2019) SD 13 (1975–2018) SC 12 (1990–2024) AR 11 (1996–2020) VA 11 (1982–2026) WV 9 (1989–2023) NH 6 (1989–2014) KY 5 (1981–2026) ND 5 (1997–2024) VI 2 (1988–1995) DE 2 (1975–2023)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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