Background
Daryl Moore was hired on an at-will basis to perform assistant-coaching duties for the 2019-2020 and 2020-2021 school years. The Coahoma County School District Board of Education set his compensation at $1,500 per school year, which he received in full. Moore asserted that the athletic director also asked him to serve as head coach of the junior-high boys’ basketball team, but that he was not paid for those additional duties.
Moore sued the Board for unjust enrichment, seeking $5,000 in allegedly unpaid head-coaching stipends. The Board moved for summary judgment under Mississippi’s minutes rule, arguing that its official minutes contained no approval of the claimed compensation. The county court denied the motion based on asserted factual disputes, and the Mississippi Supreme Court granted the Board permission to pursue an interlocutory appeal.
The Court’s Holding
The Supreme Court held that the minutes rule foreclosed Moore’s equitable claims. Public boards act only through their official minutes, and a contract with a school district—including an agreement for a coaching stipend—cannot be implied or presumed. Moore produced neither the at-will agreement he said he signed nor any minutes showing that the Board approved a $2,500 head-coaching stipend.
The Court emphasized that the Board’s minutes reflected only the approved $1,500 compensation and that a later request for additional compensation for the 2020-2021 school year failed for lack of a motion. It therefore reversed the county court’s order and rendered summary judgment for the Board. Because the minutes rule resolved the case, the Court deemed moot the Board’s alternative statute-of-limitations argument.
The majority also concluded that Mississippi Rule of Appellate Procedure 5 permitted it to hear the interlocutory appeal despite a statute prohibiting interlocutory appeals from county court. Presiding Justice Coleman dissented, arguing that the statutory prohibition deprived the Court of appellate jurisdiction.
Key Takeaways
- A school district’s agreement to pay a coaching stipend must be approved by the board and reflected in its official minutes.
- Quantum-meruit and unjust-enrichment theories cannot supply compensation that the board’s minutes never authorized.
- The Court rendered judgment for the Board because the absence of recorded approval made any factual dispute about Moore’s coaching work immaterial.
Why It Matters
The decision reinforces the strict operation of Mississippi’s minutes rule: individuals and businesses dealing with public boards must verify that the relevant agreement and compensation appear in the official minutes. Performance of services, even when requested by a school employee and beneficial to the district, does not by itself create a recoverable payment obligation.
The divided jurisdictional discussion also preserves an ongoing disagreement over whether the Supreme Court’s procedural rules can authorize interlocutory review of county-court orders despite a statutory prohibition.