Defendant-Caused Injury as the Touchstone of Venue Under Miss. Code § 11‑11‑3: Commentary on National Health Insurance Company v. Lever

I. Introduction

The Supreme Court of Mississippi’s decision in National Health Insurance Company v. Daphne Lever (Oct. 9, 2025) is a major venue decision under Mississippi Code Annotated § 11‑11‑3(1)(a)(i). The Court clarifies—and significantly narrows—when a plaintiff may rely on the “substantial event that caused the injury” language to select venue, especially in insurance coverage disputes. In doing so, the Court expressly overrules Greenwood v. Mesa Underwriters Specialty Insurance Co., 179 So. 3d 1082 (Miss. 2015), and re‑anchors venue analysis in earlier cases such as Medical Assurance Co. of Mississippi v. Myers, Hedgepeth v. Johnson, Holmes v. McMillan, and Wood v. Safeway Insurance Co.

The dispute arises from an alleged failure by National Health Insurance Company (“National Health”) to fully pay Lever’s hospital charges from St. Dominic Hospital in Hinds County. Lever sued National Health and third‑party administrator Meritain Health for breach of contract and related extra‑contractual claims, filing in Hinds County. National Health argued that venue was improper there and sought transfer to Madison County. The circuit court denied transfer; National Health obtained interlocutory review.

The core issue before the Supreme Court was whether the medical treatment Lever received in Hinds County—treatment that generated the insurance claim National Health allegedly mishandled—constituted “a substantial event that caused the injury” under Miss. Code Ann. § 11‑11‑3(1)(a)(i), thereby making Hinds County a proper venue.

The majority holds that it does not. It concludes that the relevant “substantial event” must both:

be an act or omission of the defendant, and
cause the particular injury for which the plaintiff seeks redress in the complaint.

Because Lever’s alleged injuries flow from National Health’s handling and denial of coverage, not from the medical treatment itself, the majority holds that the treatment in Hinds County cannot support venue there. Venue lies instead in Madison County. Chief Justice Randolph, joined by three other justices, dissents, arguing that the statutory text does not require the defendant to have caused the “substantial event” and that the majority improperly restricts plaintiff’s venue choice and wrongly overrules Greenwood.

II. Summary of the Opinion

A. Factual Background

Lever, a Madison County resident, received emergency and inpatient care at St. Dominic Hospital in Jackson (Hinds County) from May 5–7, 2021.
She alleges coverage under a National Health insurance policy; Meritain Health acted as third‑party claims administrator.
National Health partially paid the hospital bill. Meritain initially said the hospital was out of network, then later admitted it was in network.
Lever repeatedly contacted Meritain, submitted documentation, and sought clarification, but no full payment or adequate explanation followed.
Ultimately Meritain asserted that “the number of days for the claim to be filed had expired.”
Lever sued National Health and Meritain in the Circuit Court of Hinds County in August 2023, alleging breach of contract, breach of the covenant of good faith and fair dealing, fraud, negligence, and bad faith.
National Health and Meritain moved to dismiss or transfer venue to Madison County; the circuit court denied the motions.
Only National Health obtained permission to file an interlocutory appeal.

B. Procedural Posture and Standard of Review

On interlocutory appeal, the Court reviews:

the trial court’s decision to grant or deny a change of venue for abuse of discretion, and
the interpretation of venue statutes de novo.

This case is centrally about statutory interpretation: what § 11‑11‑3(1)(a)(i) means by “a substantial event that caused the injury.”

C. The Statutory Provision

Miss. Code Ann. § 11‑11‑3(1)(a)(i) provides that civil actions within circuit court original jurisdiction shall be commenced:

in the county where the defendant resides, or, if a corporation, in the county of its principal place of business, or in the county where a substantial alleged act or omission occurred or where a substantial event that caused the injury occurred.

Only the “substantial event that caused the injury” clause is at issue; other venue bases are not disputed.

D. Holding

The majority holds:

To qualify as “a substantial event that caused the injury,” the event must:
- be an act or omission of the defendant; and
- cause the specific injury of which the plaintiff complains in the lawsuit.
Lever’s alleged injury is not the medical treatment itself but National Health’s contract‑related acts and omissions (partial payment, denial, delay) in handling her claim.
The medical treatment at St. Dominic in Hinds County is neither an act of National Health nor the cause of the coverage‑denial injury, so it cannot support venue there.
Under the statute correctly interpreted, venue is proper in Madison County, where National Health’s relevant acts or omissions occurred (e.g., claim handling, decisions about coverage).
Greenwood v. Mesa Underwriters Specialty Ins. Co. was wrongly decided, conflicted with earlier case law, and is expressly overruled.

Accordingly, the Court reverses the Hinds County Circuit Court’s order denying the motion to transfer and remands with directions consistent with the opinion (i.e., transfer to Madison County).

E. The Dissent

The dissent argues:

Venue is a function of statute, and the plaintiff’s choice among permissible venues should be respected unless there is no credible factual basis.
The statute allows venue where “a substantial event that caused the injury” occurred; it does not require the event to be caused by the defendant.
In insurance denial cases, prior decisions (Hedgepeth, Holmes, Wood, Greenwood) accepted the location of the underlying loss or accident as a “substantial event” even though the insurer did not cause those events.
Lever incurred substantial medical bills in Hinds County, and that incurrence is a substantial event causing her financial injury and generating National Health’s contractual duty to pay.
Myers is distinguishable because it involved non‑renewal of a policy (no duty to renew) rather than denial of coverage under an existing policy.
The majority departs from the statute’s text and from consistent post‑Myers case law; Greenwood should not be overruled.

The dissent would affirm the trial court and allow Lever to proceed in Hinds County.

III. Detailed Analysis

III.A. Statutory Framework: Mississippi’s General Venue Statute

Section 11‑11‑3(1)(a)(i) gives plaintiffs several options for laying venue in circuit court civil actions:

County where the defendant resides; or
For a corporate defendant, the county of its principal place of business; or
The county where a substantial alleged act or omission occurred; or
The county where a substantial event that caused the injury occurred.

For non‑resident defendants, subsection (2) allows, if venue cannot be asserted under paragraph (1)(a), suit in the county where the plaintiff resides or is domiciled.

Mississippi precedents also emphasize that, where multiple venues are permissible, the plaintiff’s choice is ordinarily respected: “[o]f right, the plaintiff selects among the permissible venues, and his choice must be sustained unless in the end there is no credible evidence supporting the factual basis for the claim of venue.” (Upton and Tanksley, quoted in the dissent.)

The controversy in Lever turns entirely on whether Hinds County is, in fact, a permissible venue under the “substantial event that caused the injury” clause.

III.B. Precedents Cited and Their Influence on the Decision

1. Medical Assurance Co. of Mississippi v. Myers, 956 So. 2d 213 (Miss. 2007)

Myers is the majority’s principal anchor. There, Dr. Myers sued his malpractice insurer for refusing to renew his professional liability coverage. The question was whether venue lay in Holmes County (where Myers practiced, completed his application, mailed payments, received mail) or Madison County (where the insurer’s offices and decision‑making activities were located).

The Court held venue proper in Madison County, emphasizing that:

The “basis” of Myers’s claim was the insurer’s decision not to renew—an act occurring in Madison County.
Where Myers filled out the application, mailed payments, received notices, or operated a clinic did not amount to “substantial acts or injury‑causing events.”
Receiving information in a county is merely a “passive function” of the plaintiff’s presence there and does not itself constitute a substantial event causing the damages claimed.
The Court rejected reasoning that would allow venue in every county where the downstream consequences of an injury were felt, characterizing that as an impermissible expansion (the Court used the automobile accident example: one cannot create venue in every county through which an injured party subsequently travels).

From Myers, the majority derives two key propositions:

The “injury” relevant to venue is the injury for which the plaintiff seeks redress in the lawsuit, not any conceivable harm the plaintiff may experience.
The qualifying “substantial event” must be an event in which the defendant played an active role; the decision framed the relevant conduct as “MACM’s own acts or omissions.”

The majority reads Myers as deliberately focusing on the defendant’s alleged wrongful decision and treating other factual links to Holmes County as legally insignificant for venue. In Lever, this drives the majority’s conclusion that the relevant injury is the alleged breach of the insurance contract (partial payment, denial, failure to process) and that the qualifying “substantial event” must therefore be National Health’s coverage‑related conduct, not the hospital treatment itself.

2. Hedgepeth v. Johnson, 975 So. 2d 235 (Miss. 2008)

Hedgepeth involved homeowners whose property suffered damage from Hurricane Katrina. They sued State Farm for breach of contract and bad faith denial of insurance benefits. The Court held that venue in Jackson County was proper.

The majority in Lever notes that in Hedgepeth the Court focused on actions of the insurer and its agents that occurred in Jackson County:

Allegations that the insurance agent in Jackson County encouraged insurance fraud.
Allegations that two State Farm representatives were physically present in Jackson County and directly informed the plaintiffs their claim would be denied for lack of flood coverage.

While Hedgepeth also discussed Hurricane Katrina as the event generating the losses, the Lever majority reads that case as consistent with Myers because the Court identified specific insurer conduct in the county as the basis for venue, not merely the natural disaster itself.

The majority criticizes Greenwood (discussed below) for seizing on the Katrina language in Hedgepeth—“actual losses suffered due to Hurricane Katrina”—without acknowledging the insurer‑conduct aspect that truly distinguished Hedgepeth from Myers.

3. Wood v. Safeway Insurance Co., 114 So. 3d 714 (Miss. 2013)

Wood was another venue dispute involving denial of coverage. There, the Court reaffirmed that “a substantial act that caused the injury” must be an act of the defendant. The majority in Lever relies on Wood to show a consistent line of authority interpreting § 11‑11‑3 as focusing on the defendant’s conduct for venue purposes, even in coverage cases.

4. Holmes v. McMillan, 21 So. 3d 614 (Miss. 2009)

Holmes also arose out of a dispute over insurance coverage after an automobile accident. The Court stated that, in an action for denial of coverage, the “relevant acts are those associated with the denial of the claim.”

The majority in Lever deploys this line to further underscore that, in coverage litigation, the key events for venue are the insurer’s claim‑handling and decision‑making acts, not the underlying accident or loss in isolation. The majority reads Holmes as consistent with the principle that the focus is on defendant‑caused injury for which redress is sought.

5. Greenwood v. Mesa Underwriters Specialty Ins. Co., 179 So. 3d 1082 (Miss. 2015)

Greenwood is the decision the Court now expressly overrules. There, Greenwood’s business bought salvage rights to an old building in Warren County and dismantled it; the dismantling damaged an adjoining building, and Greenwood’s insurer (Mesa Underwriters) denied coverage. The Court held that venue was proper in Warren County—where the building was dismantled and where the third‑party lawsuit was filed—even though Mesa performed no acts there.

The Greenwood Court relied on Hedgepeth, emphasizing that the plaintiffs’ claims there were based, “at least in part,” on actual losses suffered due to Hurricane Katrina. It reasoned that the dismantling and resulting third‑party suit were “a substantial event that caused the injury” under the statute.

The majority in Lever disapproves this reasoning on several grounds:

Greenwood failed to identify any act or omission by Mesa in Warren County.
It imposed venue in a county based solely on the underlying accident or loss, rather than the defendant insurer’s conduct that allegedly caused the plaintiff’s actionable injury (i.e., the denial of coverage).
It misread Hedgepeth by focusing on Hurricane Katrina and ignoring or downplaying the State Farm agents’ conduct in Jackson County.
It contradicted the clear requirement, announced in Myers, Hedgepeth, Wood, and Holmes, that a substantial act must be an act of the defendant and must cause the injury sued upon.

The majority labels Greenwood an “unexplained jurisprudential creep away from established venue law” and, invoking the principle that statutory interpretations that are “mischievous in effect” may be overruled (Vicksburg Healthcare, LLC v. Mississippi State Dep’t of Health, quoting Caves v. Yarbrough), it holds Greenwood “was wrongly decided, confused the law, and should be overruled.”

III.C. The Majority’s Legal Reasoning in Lever

1. Identifying the “Injury” for Venue Purposes

The majority’s reasoning starts from a straightforward but crucial step: defining the injury that matters under § 11‑11‑3(1)(a)(i). The Court emphasizes that:

Lever’s claims are for breach of contract and related wrongs arising from National Health’s handling of her insurance claim.
She does not allege that the medical treatment itself caused any injury for which she seeks damages, nor that National Health’s acts or omissions caused any injury stemming from the medical care.

Thus, the “injury” in this case is not Lever’s physical or medical condition, but rather the financial and contractual injury from allegedly unpaid medical bills and improper claims handling. That framing tracks Myers, where the injury was the lack of renewal of coverage, not any downstream consequences of being uninsured.

2. Linking the Injury to a “Substantial Event” and to the Defendant

Having identified the nature of the injury, the majority reads the statutory phrase “a substantial event that caused the injury” in light of its prior interpretations:

The “event” must be “substantial” in relation to the case: it must have real significance to the existence of the cause of action.
The “event” must cause the injury, meaning it must be one of the causal links in the chain leading to the specific injury sued upon.
The Court’s prior cases, especially Myers, teach that the event must also be “an act of the defendant,” as opposed to merely an event in the plaintiff’s life or an independent occurrence.

Applying that framework, the majority holds that the relevant substantial events in Lever are the insurer’s acts or omissions in:

partially paying the claim,
incorrectly or inconsistently classifying the hospital as out‑of‑network and then in‑network,
failing to timely process the claim despite repeated contact, and
asserting that the claim was time‑barred.

Those acts, not the hospital treatment, allegedly caused Lever’s financial injuries. Because the treatment at St. Dominic Hospital in Hinds County is neither an act of National Health nor a causal act of National Health leading to the coverage‑denial injury, it does not qualify as “a substantial event that caused the injury” within the statute’s meaning as interpreted by the majority.

3. Distinguishing and Limiting the Scope of Prior Cases

The majority re‑aligns the caselaw by:

Reaffirming Myers as the primary guide, with its insistence that venue be based on where the defendant’s actionable conduct occurred.
Reading Hedgepeth, Holmes, and Wood through that same lens, focusing on insurer conduct rather than background events like storms or accidents.
Expressly rejecting Greenwood as an outlier and overruling it to eliminate confusion.

The upshot is a sharpened doctrinal rule: for the “substantial event that caused the injury” prong to support venue, the event must be both:

An act or omission of the defendant (or its agent), and
A cause of the specific injury pled in the complaint.

The majority concludes that the trial court, in allowing venue to rest on the hospital treatment in Hinds County, misapplied the statute under this clarified rule and thus abused its discretion in refusing to transfer.

III.D. The Dissent’s Counter‑Interpretation

1. Textual Focus on “Event” and Plaintiff’s Choice

Chief Justice Randolph’s dissent begins with two framing points:

Venue is strictly a creature of statute; where the statute allows multiple counties, the plaintiff has a right to choose among them, and that choice must be upheld if supported by credible evidence.
The standard of review distinguishes between de novo review of statutory interpretation and abuse of discretion review of the trial court’s application of that statute to the facts.

Turning to the text, the dissent stresses that § 11‑11‑3(1)(a)(i) allows suit in:

the county where a substantial event that caused the injury occurred.

The statute does not say “a substantial event caused by the defendant.” The dissent emphasizes:

The indefinite article “a” suggests multiple possible substantial events, not a single, defendant‑caused one.
Dictionaries define “event” broadly (“something that takes place; a significant occurrence”) and “substantial” as being of “considerable importance, value, degree, amount, or extent.”
Nothing in the statute’s text or definitions requires that the defendant have caused the event; the injury/damage simply needs to have been caused by the event and to have occurred in that county.

On this reading, the substantial medical treatment and resulting substantial medical debt Lever incurred in Hinds County is clearly a substantial event that caused her injury (financial liability for medical charges). That injury then triggers National Health’s alleged duty to pay under the contract. Thus, Hinds County is a permissible venue, and the plaintiff’s choice should control.

2. Reliance on Post‑Myers Cases

The dissent painstakingly recounts four major post‑Myers decisions—Hedgepeth, Holmes, Wood, and Greenwood—to show that the Court consistently allowed venue to rest on underlying events that the insurance companies did not cause:

Hedgepeth: Hurricane Katrina was “a substantial event that caused the injury” because it caused the losses giving rise to the insurance claim; State Farm obviously did not cause the hurricane.
Holmes: Venue was proper where the automobile accident occurred, because the accident was a substantial event that caused the injuries giving rise to the UM claim, even though State Farm did not cause the accident.
Wood: Similarly, the automobile accident in Smith County was recognized as the substantial event, not any act of Safeway in that county.
Greenwood: The dismantling of the building and the resultant lawsuit were held to be a substantial event causing the injury; Mesa did not cause the dismantling or the third‑party suit.

From this line of cases, the dissent concludes:

In denial‑of‑coverage cases, the Court has repeatedly allowed venue to rest on the underlying loss event, not solely on insurer conduct.
Myers is distinguishable because the insurer there had no duty to renew; the plaintiff’s claims were weak and involved “piling” of minor links to the preferred county, whereas Hedgepeth, Holmes, Wood, and Greenwood all involved clear existing coverage duties.

The dissent views the majority as effectively rewriting the statute by importing a “defendant‑caused event” requirement that appears nowhere in the text and conflicts with this more recent line of cases.

3. Application to Lever’s Facts

Under the dissent’s framework:

Lever’s three‑day stay at St. Dominic Hospital and the resulting thousands of dollars in medical bills undeniably qualify as a “substantial event” in Hinds County.
That event caused her financial injury/damage – a large medical debt – and thus directly triggered National Health’s contractual obligation to pay under the policy.
Lever has alleged a reasonable claim of liability: that National Health breached an existing contract by refusing to pay the full amount owed.

Therefore, the dissent sees Hinds County as a permissible venue under § 11‑11‑3(1)(a)(i), and the trial court’s decision to respect Lever’s venue choice is not an abuse of discretion.

III.E. Complex Concepts Simplified

1. Venue vs. Jurisdiction

Jurisdiction is a court’s legal power to hear a kind of case (subject‑matter jurisdiction) and to exercise authority over the parties (personal jurisdiction).
Venue is about which court in a particular state is the appropriate location for the case—i.e., the proper county.
In Mississippi, venue is governed by statute (such as § 11‑11‑3), and when a case is filed in the wrong county, the remedy is transfer, not dismissal (Miss. R. Civ. P. 82(d)).

2. “Substantial Event That Caused the Injury”

This statutory phrase is the central battleground in Lever.

“Event” means something that happens—a significant occurrence.
“Substantial” means important or of considerable scale or impact in the context of the dispute.
“That caused the injury” means the event must be part of the causal chain leading to the harm the plaintiff is complaining about.

The majority adds a further gloss: the event must also be an act or omission of the defendant and must cause the specific injury pled in the complaint. The dissent disputes that additional requirement and would allow any significant causal event—even one not caused by the defendant—to be used for venue.

3. Underlying Loss vs. Coverage Injury

In insurance disputes, it is critical to distinguish:

The underlying loss event (e.g., a storm, a car accident, a fire, or—here—medical treatment generating bills). This event gives rise to the insured’s claim under the policy.
The “coverage injury” (e.g., financial harm from the insurer’s refusal to pay, bad faith conduct, or delay). This is usually the injury for which the insured sues the insurer.

The majority in Lever centers venue on the coverage injury and the insurer’s acts that caused it. The dissent believes that both the underlying loss and the coverage‑related actions can be “substantial events that caused the injury” under the statute, giving plaintiffs more venue options.

4. Interlocutory Appeal

An interlocutory appeal is an appeal taken before the trial court has entered final judgment on all claims. Mississippi allows interlocutory appeals in limited circumstances (with permission), often when a legal issue—like venue—will substantially affect the course of the litigation and may be effectively unreviewable if left to the end of the case.

5. Overruling Precedent and “Jurisprudential Creep”

Courts generally follow the doctrine of stare decisis, adhering to prior decisions for the sake of legal stability. But they may overrule prior decisions when those decisions are clearly erroneous or “mischievous in effect” (i.e., they create practical problems, confusion, or injustice).

The majority characterizes Greenwood as an unexplained departure (“jurisprudential creep”) from the established pattern of venue decisions and overrules it expressly in order to restore coherence and predictability to venue doctrine under § 11‑11‑3(1)(a)(i).

III.F. Impact of the Opinion

1. Immediate Impact on This Case

The decision compels transfer of Lever’s case from Hinds County to Madison County. That shift:

Likely favors National Health, which presumably has its principal operations or claim‑handling activities in Madison County.
Imposes additional burdens on Lever, a Madison County resident who chose Hinds County, possibly for perceived plaintiff‑friendly jury pools or convenience related to witnesses at St. Dominic Hospital.
Signals that the Court will scrutinize efforts to base venue solely on where the underlying medical treatment or loss occurred if the defendant did not act there.

2. Broader Impact on Insurance Coverage Litigation

The doctrinal shift will significantly affect venue in insurance cases:

Insured plaintiffs can no longer reliably anchor venue in the county where the underlying loss occurred (e.g., the county where a house burned, a car accident happened, or medical treatment was provided), unless they can show the insurer or its agent took relevant action there.
Venue will more often be limited to:
- the county of the insurer’s principal place of business,
- the county where the insurer’s claim‑handling and decision‑making acts occurred, or
- other bases explicitly recognized by § 11‑11‑3 (e.g., defendant’s residence, or plaintiff’s residence under subsection (2) in some non‑resident contexts).
This may reduce forum‑shopping and concentration of coverage cases in historically plaintiff‑friendly counties distant from the insurer’s operations.
Third‑party administrators (like Meritain) and local agents may become more critical in venue analysis: if an agent or TPA acts in a particular county in a way that causes the coverage injury, that county may still qualify as a proper venue.

3. Implications Beyond Insurance Cases

The clarified rule that the substantial event must be an act of the defendant that causes the injury pled in the complaint has potential ripple effects in other contexts:

Contract disputes generally: A plaintiff may not ground venue in the county where the plaintiff experienced the economic effects of a breach but must look to where the defendant’s breaching conduct occurred.
Fraud and misrepresentation: Venue may be based on where the defendant made misrepresentations or omissions, rather than where the plaintiff later felt their financial consequences.
Products liability: The focus will remain on where the defendant’s relevant acts (e.g., design, manufacturing defect, distribution decisions) occurred or where the injury caused by that product occurred, but the majority’s emphasis on defendant conduct underscores that mere presence of a product in a county, without more, is insufficient.
Professional malpractice: Where the defendant’s negligent service occurred will remain a key venue anchor, consistent with the general principle that the defendant’s actionable acts define the substantial event.

4. Effect on Plaintiff’s Venue Choice Doctrine

Although the Court does not repudiate the principle that a plaintiff’s choice among permissible venues is entitled to deference, it tightens what counts as “permissible” under the statute:

The range of counties legitimately available to plaintiffs is narrower than some prior decisions, particularly Greenwood, had suggested.
Trial courts now have clearer guidance to reject venue choices that rely solely on the location of independent background events not caused by the defendant.

5. Stare Decisis and Predictability

By explicitly overruling Greenwood, the Court trades one kind of predictability (the broader set of venues recognized in Greenwood and related decisions) for another (a more consistent, defendant‑focused framework aligned with Myers and its progeny).

Lawyers litigating venue in Mississippi must now:

Carefully separate background events (e.g., accidents, storms, hospitalization) from the defendant’s actionable conduct.
Develop factual records showing where the defendant’s key acts or omissions occurred.
Expect challenges to venue based solely on the site of the underlying loss, particularly in insurance and contract cases.

IV. Conclusion

National Health Insurance Co. v. Lever sharply redefines venue under Miss. Code Ann. § 11‑11‑3(1)(a)(i) by insisting that the “substantial event that caused the injury” be both:

an act or omission of the defendant, and
a cause of the particular injury alleged in the complaint.

Under this clarified rule, Lever’s medical treatment in Hinds County—though essential background and the source of her medical debt—cannot sustain venue there because it is not conduct of National Health and did not itself constitute the coverage‑related injury she sues upon. Venue instead lies where National Health’s acts or omissions in processing, partially paying, and denying the claim occurred, which the Court identifies as Madison County.

The decision marks an explicit and significant course correction in Mississippi venue law. By overruling Greenwood and reading Hedgepeth, Holmes, and Wood through the lens of Myers, the Court narrows plaintiffs’ venue options, especially in insurance coverage disputes, and elevates defendant‑centric causation as the touchstone for the “substantial event” prong. The dissent warns that this approach understates the statutory text, constrains plaintiff autonomy in venue selection, and abandons a line of cases that had treated underlying loss events as viable venue anchors, even when not caused by insurers.

Going forward, Lever stands as a leading authority on Mississippi venue, requiring litigants and trial courts to focus on where the defendant’s actionable conduct occurred and how that conduct caused the specific injury sued upon. It strengthens the conceptual link between the locus of wrongful conduct and the proper forum, reshaping strategic decisions about where civil actions—particularly coverage and contract cases—may be filed and litigated in Mississippi’s circuit courts.

Defendant-Caused Injury as the Touchstone of Venue Under Miss. Code § 11‑11‑3: Commentary on National Health Insurance Co. v. Lever