In In re Estate of Randle, the Supreme Court of Mississippi reviewed the classification and distribution of settlement proceeds from a wrongful-death claim. The case centered on whether such proceeds should be treated as estate assets or distributed directly to wrongful-death beneficiaries. The Court reversed the judgments of both the chancery court and the Court of Appeals and clarified the procedures courts must follow when determining beneficiaries under Mississippi’s wrongful-death statute.
Lester Randle died intestate in 2009. He was survived by his second wife, Dorothy Randle, and their son, Raymond. He also had two children from a previous marriage, Tumika and Sylvester, who were listed on his birth certificate and received child support from him during his life. In 2018, Dorothy filed a petition to open Lester’s estate, stating the only potential asset was a claim for unliquidated damages related to his death. A petition to determine heirs followed.
Dorothy later filed a wrongful-death lawsuit and recovered $67,500.25 in settlement proceeds. She sought a judgment declaring that Tumika and Sylvester were not heirs and thus not entitled to any of the proceeds. During hearings, DNA evidence was introduced, suggesting that Raymond was not biologically related to Tumika and Sylvester. The chancery court ruled that Dorothy and Raymond were the only heirs-at-law and awarded them the settlement proceeds.
The chancery court determined heirship under Mississippi Code Sections 91-1-1 to -31 and considered the wrongful-death proceeds as estate assets. It concluded that Tumika and Sylvester were not heirs-at-law based on DNA results. The Court of Appeals affirmed.
The Supreme Court held that the lower courts erred in classifying the settlement proceeds as part of the estate. Under Mississippi Code Section 11-7-13, wrongful-death damages are the property of statutory beneficiaries, not the decedent's estate. The Court cited prior cases confirming that only certain expenses, such as funeral and final medical costs, are recoverable by the estate, while other damages go directly to beneficiaries.
The Court clarified that a chancery court's role in wrongful-death matters is limited to three functions: opening the estate to allow beneficiaries to pursue a claim, approving settlements involving minors, and determining the wrongful-death beneficiaries. In this case, the chancery court exceeded its authority by distributing proceeds based on heirship under the probate code rather than determining the proper beneficiaries under Section 11-7-13.
The Court noted that wrongful-death and descent statutes differ and may lead to different results. Specifically, the wrongful-death statute treats children born during a marriage as legitimate, which applied to Tumika and Sylvester. There was no legal action taken during Lester’s life to disestablish their paternity.
The Supreme Court reversed the chancery court’s order and the appellate decision. It remanded the case for proper determination of wrongful-death beneficiaries under Mississippi Code Section 11-7-13. The ruling reaffirms that wrongful-death proceeds are not estate property and must be distributed according to the statutory framework governing wrongful-death claims.
If you have questions about wrongful death claims or the proper handling of settlement proceeds, the team at Whitcomb, Selinsky, PC can help. Our attorneys offer guidance on beneficiary rights and the distribution of wrongful-death awards under state law.