The Mississippi Court of Appeals has upheld a lower court's decision to dismiss a slander lawsuit filed by J.T. Robinson against Andrew C. Sartin. The court ruled that Robinson's complaint was filed one day too late, which is significant because it highlights the importance of adhering to legal deadlines in defamation cases. This ruling affects individuals who may consider pursuing similar claims, emphasizing the need for timely action.
The case, known as J.T. Robinson v. Andrew C. Sartin, was filed under docket number 2025-CA-00412-COA. The dispute arose after Sartin, a commissioner with the Natchez Preservation Commission, made comments about Robinson's property, Nellie’s, during a public meeting. Robinson claimed these remarks were slanderous and led to his lawsuit against Sartin. The Adams County Circuit Court had granted summary judgment in favor of Sartin, leading to Robinson's appeal.
At the heart of the dispute is the timeline of events. Robinson owns the property known as Nellie’s, located at 416 N. Rankin Street in Natchez. During a meeting on September 14, 2022, Sartin stated he had received calls regarding the condition of Nellie’s and suggested it be added to a list of properties at risk of demolition due to neglect. Robinson, who was present at the meeting, did not expect his property to be discussed. A year later, on September 15, 2023, he filed a slander complaint against Sartin, claiming the comments were damaging to his reputation.
However, Sartin's legal team argued that Robinson's complaint was filed after the one-year statute of limitations for slander claims had expired. The circuit court agreed, stating that Robinson's complaint was filed one day too late. Robinson contended that republication of Sartin's statements by the Natchez Democrat constituted a continuing tort, which he believed would toll the statute of limitations. Nevertheless, the court found that the initial slander claim had already expired.
The court ruled, "Robinson’s complaint was filed one day too late. It is barred by the statute of limitations, and we affirm the circuit court’s grant of summary judgment on that ground." The judges involved in the ruling included Chief Justice Barnes, and Justices McCarty and Lassitter St. Pé. They unanimously agreed on the decision.
In addition to the statute of limitations issue, the court also addressed Robinson's request to amend his complaint to include statements allegedly made by Sartin to the Natchez Democrat on September 30, 2022. The circuit court denied this request, stating that the new statements did not create a new cause of action for slander. The court emphasized that the law recognizes defamation as complete when the statement is first made, regardless of subsequent publications.
The court explained, "A new action does not accrue each time there is a subsequent republication of offensive words." This reinforces the principle that individuals must act promptly when they believe they have been defamed. Robinson's attempt to argue that the statements were slanderous per se because they implied he was committing a crime was also dismissed. The court found that he could not prove the elements of defamation based on Sartin's comments.
This ruling has broader implications for individuals considering legal action for defamation. It underscores the critical nature of filing claims within the prescribed time limits and the challenges involved in proving slander. Those who believe they have been wronged must be vigilant in documenting their claims and acting swiftly to protect their rights.
Looking ahead, Robinson's options for appeal are limited since the court has affirmed the lower court's ruling. There are no indications of a related case pending that could affect this decision. The outcome serves as a reminder of the complexities involved in defamation cases and the importance of understanding legal timelines.
Read Next
Mississippi court reverses manslaughter conviction of Ryals
Mississippi court reverses summary judgment in lease dispute
Mississippi court affirms termination of father's parental rights
Illinois Court Upholds $7.5 Million Verdict in Medical Case
Court upholds ruling in Sharpe v. Peterson personal injury case
California Court dismisses appeal from Delano School District










