Expired Judgments and Trust Funds: Pro Rata Distribution of MDL Refunds in Thompson & Dixon v. Estate of Lee

I. Introduction

In Gloria Thompson and Deborah Dixon v. The Estate of Herbert Lee, Jr., Deceased, and Sharon Gallagher‑Lee, Administratrix (Supreme Court of Mississippi, Nov. 13, 2025), the Court addressed an unusual collision between:

• the expiration of a money judgment under Mississippi’s seven‑year limitation period, and
• the ongoing existence of funds held in trust/escrow from earlier multidistrict litigation (“MDL”) settlements.

The central question was: Who is entitled to a long‑held MDL fee refund—approximately $98,000—after:

• the attorney who mishandled the funds (Herbert Lee) died,
• a judgment against him in favor of his clients (Thompson and Dixon) expired without renewal, and
• the MDL trustee interpleaded the refund into a Mississippi chancery court?

The chancellor awarded the entire refund to Lee’s estate, relying on language in an earlier, now‑expired judgment and a prior Supreme Court summary suggesting that Lee was “entitled to the refund.” The Supreme Court of Mississippi reversed, holding that:

• Rights under the old judgment had been extinguished by statute, for both sides, and
• The refund money, held in trust, must instead be distributed according to the original contributions into the MDL fund: 45% to Lee’s estate and 55% to Thompson and Dixon.

This opinion clarifies that in Mississippi:

• An expired judgment cannot be used to reallocate ownership of trust/escrow funds.
• Yet, the underlying property rights in those funds, traceable to prior factual findings, can still be vindicated.

II. Factual and Procedural Background

A. The Fen‑Phen Litigation and the MDL Fee

In 2001, attorney Herbert Lee, Jr. represented Gloria Thompson, Deborah (Debra) Dixon, and eleven other clients in “fen‑phen” diet‑drug litigation against a pharmaceutical manufacturer in the Circuit Court of Holmes County, Mississippi.

• The case settled for a gross amount of $32 million.
• 6% of the settlement (approximately $1.92 million) was deducted as a “common benefit” MDL fee, to compensate work performed in related federal multidistrict litigation.
• Lee structured the payment of this MDL fee as:
  • 45% paid by Lee (from his attorney’s fee), and
  • 55% paid “off the top” from the clients’ settlement proceeds.
• The MDL fee was deposited into a Multi‑District Litigation Fee and Cost Account (“MDL fund”), administered by an MDL trustee.

After the settlements, the MDL trustee determined that one‑third of all MDL deposits would be refunded. That meant 2% of the $32 million settlement was refunded to Lee. He then:

• Kept 45% of the refund for himself as “attorney’s fees,” and
• Distributed the remaining 55% to clients per capita—each of the 13 clients received one‑thirteenth—rather than in proportion to their individual settlement amounts.

Thompson and Dixon objected to this handling of both:

• Lee’s overall attorney’s fee, and
• His allocation of the MDL refund.

B. The First Appeal – Lee I

In Lee v. Thompson (Lee I), 43 So. 3d 1104 (Miss. 2010), the Supreme Court held:

• The relevant MDL pretrial orders required that the MDL fee be paid entirely from the attorneys’ fees, not from the clients’ recoveries.
• Consequently, Lee’s original 45%/55% split of the MDL fee (with the clients paying 55% off the top) was contrary to the MDL orders.
• The MDL refund had been distributed incorrectly:
  • It should have been distributed pro rata based on each client’s settlement amount,
  • Not per capita in equal shares.

The Court remanded for the trial court to:

• Determine whether the settlement had been distributed in accordance with the MDL pretrial orders, and
• Order a proper redistribution if it had not.

C. The Second Appeal – Lee II and the 2012 Orders

On remand, the trial court found that Lee had not paid or distributed the MDL fee in accordance with the MDL orders. It entered a May 1, 2012 order which:

• Calculated that Lee owed:
  • $420,000 to Thompson, and
  • $180,000 to Dixon,
  representing the difference between the attorney’s fees they actually paid and what should have been paid under the MDL orders.
• Described Lee’s scheme, noting that he:
  • Took a 45% fee from the gross settlement without crediting clients for the MDL fee, and then
  • Took 45% of the MDL refund again, before distributing the rest to clients per capita.
• Directed that the remaining MDL refund amounts in trust for Thompson and Dixon be disbursed to Lee “after payment of the above damages.”

Thompson and Dixon asked the court to modify the order so they would receive the refund as a credit against the judgment. The trial court denied the request in a July 3, 2012 order, reasoning that recalculation of MDL fees “necessarily entitles [Lee] to the entirety of any refunds,” but again indicating that he would receive those refunds only after paying the damages.

A final judgment was entered on August 1, 2012, and appealed. In Lee v. Thompson (Lee II), 167 So. 3d 170 (Miss. 2014), the Supreme Court:

• Affirmed the trial court’s judgment in favor of Thompson and Dixon, and
• Summarized the trial court’s view as: “because under the appropriate calculation Lee was responsible for the entire MDL fee, he was entitled to the refund.”

The mandate in Lee II issued on July 3, 2014. Critically, however, the underlying May 1, 2012 order conditioned Lee’s entitlement to the refund on his prior payment of the damages owed to Thompson and Dixon—something he never did.

D. Post‑Appeal Events: Federal Suit and Bar Discipline

In 2015, Lee filed a 42 U.S.C. § 1983 action in federal court against Thompson, Dixon, and several Mississippi Supreme Court justices, challenging their roles in the state‑court decisions. The federal court dismissed his claims.

In 2017, Lee was publicly reprimanded and fined by the Mississippi Bar for failing to properly account for the MDL funds in the diet‑drug litigation, confirming the professional‑discipline consequences of his handling of the funds.

E. Lee’s Death, the Estate, and the Interpleaded MDL Refund

Lee died on August 22, 2019. His wife, Sharon Gallagher‑Lee, petitioned to open his estate in the Hinds County Chancery Court on December 29, 2021; letters of administration issued March 29, 2022.

On August 1, 2023, Sharon (as administratrix) filed a Petition to Bar Purported Claims against Thompson and Dixon, arguing:

• The seven‑year limitation period on judgments in Mississippi Code § 15‑1‑43 had expired on the 2012 money judgment in favor of Thompson and Dixon, and
• Therefore, they could assert no claims against the estate based on that judgment.

Thompson and Dixon responded, and separately sought an order directing the MDL escrow agent (trustee) to release the remaining MDL refund directly to them. Meanwhile, the MDL trustee, recognizing competing claims, filed an interpleader and paid $98,461.54 into the registry of the Hinds County Chancery Court in August 2024.

F. The Chancellor’s Ruling

On February 25, 2025, the chancellor:

• Denied Thompson and Dixon’s request for release of the MDL funds to them,
• Granted the estate’s petition to bar their claims, and
• Ordered that the MDL refund be distributed entirely to Lee’s estate.

The chancery court held that:

• The August 2012 final judgment converted Thompson and Dixon’s claims into a judgment which expired on July 7, 2021, under § 15‑1‑43.
• Thompson and Dixon never renewed the judgment; thus, their rights to execute on it were extinguished by § 15‑1‑3.
• Relying on the Supreme Court’s summary in Lee II, the chancellor concluded that the circuit court and Supreme Court had already determined that Lee was “entitled” to the MDL refund; hence, his estate should receive it once Thompson and Dixon’s judgment rights lapsed.
• Any argument about lack of notice of the estate opening was immaterial because the judgment had already expired before the estate was opened.

The chancellor certified this ruling as a final judgment under Mississippi Rule of Civil Procedure 54(b). Thompson and Dixon appealed.

III. Summary of the Supreme Court’s 2025 Decision

The Supreme Court of Mississippi reversed and remanded.

The Court held:

1. The 2012 money judgment in favor of Thompson and Dixon has expired.
   • They did not renew it within seven years, so under § 15‑1‑43 and § 15‑1‑3, the rights and remedies under that judgment are extinguished.
   • The chancellor was correct on this point.
2. The chancellor erred in awarding the entire MDL refund to Lee’s estate based on the expired judgment.
   • The underlying May 1, 2012 order (not fully quoted in Lee II) made Lee’s entitlement to the refund expressly conditional on his first paying damages to Thompson and Dixon.
   • Because the judgment has now expired, the estate cannot enforce any supposed entitlement under it either.
3. The MDL refund must be distributed based on original contributions to the MDL fee.
   • It is undisputed, and stipulated, that:
     • Lee paid 45% of the MDL fee, and
     • Thompson and Dixon together paid 55%.
   • The funds were held in trust, and were always 55% the clients’ money and 45% Lee’s money.
   • The Court ordered that the funds now in the chancery court registry be distributed:
     • 45% to Lee’s estate, and
     • 55% to Thompson and Dixon.

The Court underscored that:

• It was improper to use an expired judgment to give the estate the full refund, and
• It would be equally improper to give Thompson and Dixon the entire refund as an equitable workaround for the judgment they allowed to lapse.

Instead, the Court treated the refund as trust property whose ownership is determined by the parties’ original contributions, not by the now‑expired judgment.

IV. Precedents and Authorities Cited

A. Lee I – MDL Fee Must Come from Attorney’s Fees

In Lee v. Thompson (Lee I), 43 So. 3d 1104 (Miss. 2010), the Court interpreted MDL pretrial orders governing the fen‑phen litigation. The key holdings:

• The MDL “common benefit” fee was to be taken entirely from attorneys’ fees.
• Lee had unlawfully shifted 55% of that fee onto his clients’ recoveries.
• The MDL refund, once paid back, had to be distributed pro rata, based on clients’ settlement amounts, not per capita in equal shares.

These holdings established that Lee’s earlier handling of both the MDL fee and the refund was improper. They also provided the foundation for later findings that:

• Lee had effectively used client funds to pay what should have been an attorney‑only expense, and
• He then recaptured 45% of the very refund that included those same client funds.

B. Lee II – Affirmance and the “Entitlement” Language

In Lee v. Thompson (Lee II), 167 So. 3d 170 (Miss. 2014), the Supreme Court:

• Affirmed the trial court’s judgment awarding $420,000 to Thompson and $180,000 to Dixon.
• Recounted that the trial court had determined Lee to be responsible for the entire MDL fee under the MDL orders.
• Summarized that, because Lee was responsible for the entire MDL fee, the trial court had found him “entitled to the refund.”

In the present case, the Court acknowledges that this summary was accurate but incomplete. The original trial‑court order made Lee’s entitlement to the refund conditional on his payment of damages to Thompson and Dixon. That condition was lost in the shorthand summary, which later produced the “telephone game” effect the Court alludes to.

Even so, the Court treats the determination that Lee was “responsible for the entire MDL fee” and notionally “entitled to the refund” as the law of the case, meaning that point is not re‑litigated. What changes here is the temporal and procedural context—Lee is deceased, the judgment has expired, and the funds remain in trust.

C. Statutory Framework: §§ 15‑1‑43 and 15‑1‑3

Two Mississippi statutes are central:

• Miss. Code Ann. § 15‑1‑43 (Rev. 2019):
  • Applies to “[a]ll actions founded on any judgment or decree” rendered by a Mississippi court of record.
  • Requires such actions to be brought within seven years of:
    • the rendition of the judgment, or
    • the last renewal of the judgment, whichever is later.
• Miss. Code Ann. § 15‑1‑3 (Rev. 2019):
  • Provides that completion of a limitation period “defeat[s] and extinguish[es] the rights as well as the remedy” for the barred claim.

These provisions do not merely bar collection efforts; they extinguish the underlying rights created by the judgment once the limitations period passes without renewal.

D. Standard of Review Cases: Ruff and Biglane

The Court invokes its familiar chancery standard of review, citing:

• Ruff v. Estate of Ruff, 989 So. 2d 366 (Miss. 2008), and
• Biglane v. Under the Hill Corp., 949 So. 2d 9 (Miss. 2007).

The rule: the Supreme Court will not disturb a chancellor’s factual findings supported by substantial evidence unless the chancellor:

• abused his or her discretion,
• was manifestly wrong or clearly erroneous, or
• applied an erroneous legal standard.

In this case, the Court finds that the chancellor applied an erroneous legal standard to the questions of:

• the effect of the expired judgment, and
• the ownership of MDL refund funds held in trust.

E. Related Context: The Federal Case and Bar Discipline

The opinion also references:

• Lee v. Weill, No. 3:14‑cv‑652‑DPJ‑FKB, 2015 WL 224816 (S.D. Miss. Jan. 15, 2015) – Lee’s unsuccessful § 1983 action challenging the state‑court outcomes; and
• The Mississippi Bar’s 2017 public reprimand and fine against Lee for failure to properly account for the MDL funds.

These references underscore that the MDL fee issue has long been a matter of both civil liability and professional responsibility, but they play only indirect roles in the current entitlement and limitation analysis.

V. Legal Reasoning in Detail

A. Effect of Judgment Expiration: Rights and Remedies Extinguished

The Supreme Court first confirms that the chancellor was correct in one critical respect: Thompson and Dixon’s judgment has expired.

• The Court treats the relevant date as seven years after the mandate in Lee II (July 2014), putting the expiration in July 2021.
• Thompson and Dixon admit that they failed to renew the judgment within the seven‑year period authorized by § 15‑1‑43.

Applying § 15‑1‑43 together with § 15‑1‑3, the Court holds that:

• The expiration of the seven‑year period “extinguished the rights and remedies” afforded by that judgment.
• Thompson and Dixon can no longer:
  • execute on the judgment,
  • pursue actions founded on that judgment, or
  • rely on it as a source of enforceable legal rights.

In other words, the Court does not invent any special exception to the judgment‑limitation regime; it applies the statute as written. The money judgment is dead.

B. Why the Chancellor Erred: Misapplying an Expired Judgment

The key error of the chancellor was to treat:

• The expired 2012 judgment, and
• The Supreme Court’s shorthand description in Lee II,

as establishing a present, enforceable right in Lee (and thus his estate) to the entire MDL refund.

The Supreme Court rejects this on two independent grounds:

1. The actual 2012 trial‑court order was conditional and was misread.
   • The May 1, 2012 order (which the Court had to pull from its own records because it was not re‑filed in the current case) explicitly states that the MDL refund is to be disbursed to Lee “after payment of the above damages.”
   • It is undisputed that Lee never paid Thompson and Dixon the $420,000 and $180,000 awarded to them.
   • Thus, even if the judgment were still valid, giving the estate the refund without satisfaction of the damages would contradict the plain terms of the order that Lee himself sought to enforce.
2. The judgment’s expiration extinguished rights for both sides.
   • Section 15‑1‑3 makes clear that completion of the limitations period extinguishes the rights under a judgment, not just the creditor’s remedies.
   • If Thompson and Dixon cannot enforce the judgment for damages, then the estate likewise cannot enforce any “entitlement to the refund” that arose solely under that same judgment.
   • To allow the estate to rely on the expired judgment to its own benefit would be to apply the limitation period asymmetrically, contrary to the statute’s text.

Accordingly, the Court finds the chancellor’s decision to award the entire MDL refund to the estate based on the expired judgment to be a manifest error of law.

C. Clarifying the 2012 Order and the “Telephone Game”

A notable feature of the opinion is its candid acknowledgment of how appellate summaries can unintentionally distort trial‑court rulings over time. In Lee II, the Court had summarized the trial court’s view as:

“The trial court found that, because under the appropriate calculation Lee was responsible for the entire MDL fee, he was entitled to the refund.”

In the present case, the Court concedes that this was only a partial encapsulation of the 2012 order. The full order:

• Recognized Lee’s responsibility for the entire MDL fee under the MDL pretrial orders.
• Thus recognized a conceptual entitlement for Lee to recoup the MDL fee from the refund.
• But then expressly conditioned any distribution of the MDL refund to Lee on his prior payment of damages to Thompson and Dixon.

The Court likens what happened between 2012 and 2025 to the children’s game of “Telephone”: a phrase is whispered from person to person, and by the time it reaches the last participant, it is often altered. Here, the “phrase” was the nature of Lee’s entitlement to the refund; over time, through partial quotations, it matured into a mistaken belief that he had an unconditional right to the entire refund.

The Court uses this metaphor to underscore a broader doctrinal point: short‑hand appellate characterizations cannot displace the actual text of trial‑court orders, especially when those orders are directly relevant to current entitlement questions.

D. Distinguishing Judgment‑Based Rights from Property‑Based Rights

The decision draws an important distinction between:

• Judgment‑based rights – the rights conferred by the 2012 money judgment (e.g., the right of Thompson and Dixon to collect damages from Lee, the trial court’s direction about post‑payment disposition of the MDL refund); and
• Property‑based rights – the underlying ownership of the money in the MDL trust, based on who originally contributed what portion of the MDL fee.

The Court holds:

• The judgment‑based rights have been extinguished by § 15‑1‑43 and § 15‑1‑3.
• The property‑based rights—who actually owns the money in the MDL refund fund—are not “founded on” the judgment in the sense contemplated by § 15‑1‑43.

In particular:

• The MDL refund funds were “always 55 percent Thompson and Dixon’s money,” and 45 percent Lee’s money, because those percentages represent the original contributions to the MDL fee.
• The earlier rulings, and the parties’ stipulations, establish those percentages as historic fact.
• Even though the judgment awarding money damages has lapsed, nothing in § 15‑1‑43 transforms the clients’ 55% contribution into property of the attorney merely because time passed.

Thus, the Court severs the question of collecting a judgment from the question of who owns money held in trust. The former is time‑barred; the latter is not.

E. Determining Entitlement to the MDL Refund: Tracing Contributions

Having rejected both extreme positions—that the estate should receive 100% of the refund, or that Thompson and Dixon should receive 100% as a disguised substitute for their expired judgment—the Court adopts a tracing approach.

Guided by the established and stipulated facts, the Court holds:

• At the time the MDL fee was paid:
  • Lee contributed 45%, and
  • Thompson and Dixon (together with other clients, but as relevant here) contributed 55% from their settlement proceeds.
• Therefore, of the MDL fee that was later refunded, 45% reflects money that was always Lee’s (i.e., his own fee share), and 55% reflects money that was always the clients’.
• The MDL funds were held in an escrow/trust account. Ownership of that trust res did not change simply because the judgment expired or because of prior misallocations by Lee.

Accordingly, the Court orders that the interpleaded funds in the chancery court registry be distributed:

• 45% to the Estate of Herbert Lee, Jr., and
• 55% to Thompson and Dixon.

The Court explicitly notes that:

• Giving all of the funds to the estate would be:
  • Contrary to the expired judgment’s own terms, and
  • A misuse of an extinguished judgment as a sword for the debtor’s benefit.
• Giving all of the funds to Thompson and Dixon would:
  • Effectively resurrect their expired judgment in equitable form, and
  • Grant them a remedy that the legislature has chosen to limit by statute.

The pro‑rata distribution thus reflects a principled middle ground, anchored in property law rather than judgment enforcement.

VI. Complex Concepts Simplified

A. Multi‑District Litigation (MDL) and “Common Benefit” Fees

In large, nationwide litigations—like the fen‑phen diet‑drug suits—cases from many states are sometimes consolidated in federal court as Multi‑District Litigation (MDL). To avoid duplicating work, a core group of attorneys performs discovery and other tasks for the benefit of all plaintiffs.

To compensate those attorneys, courts often impose a “common benefit” assessment on all plaintiffs’ recoveries. That assessment is what the opinion refers to as the “MDL fee”.

In this case:

• The MDL fee was 6% of the total settlement.
• Under the MDL court’s pretrial orders, that 6% had to come from the attorney’s share of the recovery, not the clients’ share.

B. Pro Rata vs. Per Capita Distribution

The Court contrasts two ways of dividing money among multiple people:

• Pro rata distribution – Each person receives a share proportional to their individual stake.
  • If Client A’s settlement is twice as large as Client B’s, A gets twice as much of the refund as B.
• Per capita distribution – Each person receives an equal share, irrespective of differences in individual stakes.

Lee wrongly distributed the MDL refund per capita to 13 clients, instead of pro rata according to each client’s settlement amount, contrary to the MDL court’s orders and general equity principles.

C. Interpleader and Court Registry

An interpleader is a procedure used when a party (often a stakeholder or trustee) holds money or property that is claimed by two or more others. To avoid double liability, the stakeholder:

• Deposits the funds with the court (often into the court registry), and
• Asks the court to decide who among the claimants is entitled to the money.

Here, the MDL trustee interpleaded the remaining MDL refund—$98,461.54—into the Hinds County Chancery Court registry, recognizing that both the estate and Thompson and Dixon asserted claims to it.

D. Statute of Limitations on Judgments in Mississippi

Unlike most claims—for which a statute of limitations governs how long you have to file a lawsuit—judgments themselves have a separate time limit for enforcement in Mississippi.

• Under § 15‑1‑43, actions founded on a judgment must be brought within seven years of the judgment’s rendition (or last renewal).
• Under § 15‑1‑3, when that period elapses, both the remedy and the underlying right created by the judgment are extinguished.
• Judgments can often be renewed—typically by filing a new action on the judgment or obtaining some statutorily allowed renewal mechanism—before they expire.

Thompson and Dixon did not renew their 2012 judgment, so by 2021, they lost the ability to enforce it against Lee or his estate.

E. Law‑of‑the‑Case Doctrine

The law‑of‑the‑case doctrine prevents parties from re‑litigating legal issues that have already been decided earlier in the same case (or a closely related earlier appeal in the same litigation).

In this opinion:

• The Court acknowledges that its prior holding in Lee II—that Lee was “responsible for the entire MDL fee” and thus “entitled to the refund”—is puzzling in light of his misuse of client funds, but nonetheless treats it as the law of the case.
• However, law of the case does not prevent the Court from:
  • Consulting the full text of the 2012 orders to clarify conditions attached to Lee’s entitlement, or
  • Re‑evaluating how that entitlement interacts with an expired judgment and a later interpleader over trust funds.

VII. Impact and Implications

A. For Judgment Creditors and Estates

The decision sends a clear message to both creditors and estates:

• Judgment creditors (like Thompson and Dixon once were):
  • Must vigilantly monitor limitation dates.
  • If they allow judgments to expire without renewal, they cannot later ask courts to manufacture substitute remedies that effectively resurrect those judgments.
• Debtors and estates:
  • Cannot weaponize an expired judgment in their favor.
  • If a judgment’s terms would have required them to do something (e.g., pay damages before receiving funds), its expiration eliminates their ability to enforce the favorable parts as well.

This symmetric application of § 15‑1‑3 reinforces that limitation statutes extinguish rights on both sides and are not to be used tactically by the party who benefitted from non‑compliance.

B. For Trust, Escrow, and Interpleader Practice

From a trust and escrow perspective, the opinion underscores:

• Courts will look to the origin of funds in an escrow or trust account when resolving competing claims in an interpleader.
• Even if related litigation has produced judgments that later expire, the ownership of trust property remains determined by:
  • who originally contributed funds, and
  • the terms under which those contributions were made.
• A trustee or escrow agent can safely interplead disputed funds into court and let the court apply equitable tracing principles, as was done here.

This ruling is particularly relevant in complex, long‑running litigations where funds may remain in escrow for years or even decades while related disputes and appeals play out.

C. For Attorney Fee Disputes and Professional Responsibility

The opinion reinforces several themes relevant to attorney‑fee practices:

• Attorneys in MDL or coordinated mass‑tort litigation must strictly adhere to MDL court orders regarding:
  • which portion of the recovery funds MDL assessments, and
  • how related refunds are to be allocated among clients.
• The Court is willing to scrutinize complex fee arrangements and re‑characterize them when they effectively lead to clients bearing costs that MDL orders assign to attorneys.
• Mismanagement of such funds can result in:
  • civil liability,
  • disciplinary action (as with the Bar’s reprimand of Lee), and
  • long‑tail disputes even after the attorney’s death and the expiration of related judgments.

D. For Interpretation of Prior Appellate Language

Finally, the decision is notable for its methodological humility. It acknowledges that:

• Short, summary phrases in appellate opinions—like “Lee was entitled to the refund”—are not substitutes for the underlying orders themselves.
• When later courts must implement or interpret prior relief, they should:
  • Consult the actual text of the trial‑court orders, and
  • Guard against over‑reading earlier appellate summaries as if they were comprehensive codifications of those orders.

In doing so, the Court models a careful approach to precedent interpretation, emphasizing fidelity to the original record over reliance on necessarily compressed descriptions in prior appellate opinions.

VIII. Conclusion: Key Takeaways

The Mississippi Supreme Court’s decision in Thompson & Dixon v. Estate of Lee establishes several important principles:

• Judgments expire, property rights do not. Once a money judgment expires under § 15‑1‑43 and § 15‑1‑3, the rights and remedies under that judgment are extinguished for both creditor and debtor. But ownership of funds held in trust or escrow is determined by original contributions and contractual or court‑ordered terms—not by the continuing vitality of a judgment.
• Expired judgments cannot be used as swords. A debtor or estate cannot invoke the favorable portions of an expired judgment (e.g., language suggesting entitlement to a refund) while ignoring its conditions and the extinguishment of rights under that same judgment.
• Trust funds must be returned in accordance with their source. Where funds are held in trust pending resolution of disputes, and prior proceedings establish (or parties stipulate) who contributed what, courts should distribute the funds pro rata according to those contributions unless another valid, enforceable legal directive controls.
• Equity cannot override clear statutory limits. Courts will not grant an “equitable” windfall to a judgment creditor whose judgment has expired, nor will they ignore statutory extinguishment by allowing the debtor’s estate to profit unjustly from an expired judgment.
• Careful reading of prior orders matters. Appellate summaries are not a substitute for the underlying trial‑court orders. When present disputes turn on the exact content of past relief, courts must go back to the original orders rather than rely solely on abbreviated characterizations.

By reversing the chancellor and directing that 45% of the MDL refund go to Lee’s estate and 55% go to Thompson and Dixon, the Court harmonizes Mississippi’s strict judgment‑limitation regime with basic principles of trust and property law. The case thus stands as a significant precedent on how expired judgments interact with funds held in trust, and on the proper method for resolving entitlement disputes in long‑running, complex litigation.