Justia Tennessee Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the court of appeals reversing the conclusion of the trial court that Plaintiff failed to establish Defendant's requisite minimum contacts with Tennessee, and thus the court lacked personal jurisdiction over Defendant with respect to Plaintiff's suit, holding that the trial court correctly dismissed Plaintiff's complaint.Plaintiff, a Tennessee resident, hired Defendant, an Alabama corporation with its principal place of business in Alabama, to build a house on a parcel of land in Alabama. Upon becoming dissatisfied with the quality and expense of the construction work Plaintiff filed suit in the Davidson County Chancery Court. The trial court granted Defendant's motion to dismiss for lack of jurisdiction, concluding that Defendant's contacts with Tennessee were minor and attenuated. The court of appeals reversed. The Supreme Court reversed, holding that Plaintiff failed to establish a prima facie case of the minimum contacts necessary for a Tennessee court to exercise specific personal jurisdiction over Defendant. View "Baskin v. Pierce & Allred Construction, Inc." on Justia Law

The Supreme Court reversed the judgment of the court of appeals as to the applicability of the economic loss doctrine in this case, holding that the economic loss doctrine applies only in products liability cases and should not be expanded to apply outside the products liability context.In the underlying suit brought by a drywall subcontractor against a general contractor under theories of breach of contract and tort a jury awarded compensatory and punitive damages to the subcontractor. The court of appeals affirmed in part the award of compensatory damages for breach of contract, dismissed the tort claim, and reversed the award for punitive damages, holding that the economic loss doctrine applied outside the products liability context when the contract was negotiated between sophisticated commercial entities. The Supreme Court reversed, holding (1) the economic loss doctrine only applies in products liability cases and should not be extended to other claims; and (2) the economic loss doctrine did not bar the subcontractor's recovery of compensatory and punitive damages based on its tort claim. View "Commercial Painting Co. v. Weitz Co., LLC" on Justia Law

On appeal from the trial court's denial of a motion to compel arbitration in this wrongful death lawsuit brought against Defendant, a nursing home, the Supreme Court held that Defendant did not meet the requirements for limited statutory immunity from civil liability under either Tennessee's Durable Power of Attorney for Health Care Act, Tenn. Code Ann. 34-6-201 to -218, or the Health Care Decisions Act, Tenn. Code Ann. 68-11-1801 to -1815.After a resident of the nursing home died his estate brought the underlying wrongful death suit. Defendant moved to compel arbitration based on an arbitration agreement executed by Plaintiff on the decedent's behalf pursuant to a durable power of attorney for health care (POA) form. Plaintiff objected, arguing that the decedent did not have the mental capacity to appoint an agent when he executed the POA. The trial court concluded that the POA was invalid. The court of appeals reversed, concluding that the trial court erred in looking beyond the face of the POA to determine whether Defendant had the mental capacity to execute it. The Supreme Court reversed and affirmed the trial court, holding that the trial court did not err in considering evidence on whether the principal had the requisite mental capacity to execute the POA. View "Welch v. Oaktree Health & Rehabilitation Center LLC" on Justia Law

The Supreme Court reversed the decision of the court of appeals upholding that trial court's determination that the plaintiff homeowner's award of attorneys fees and costs under Tenn. Code Ann. 20-12-119(c) was limited to those incurred after the date the defendant contractor filed an amended countercomplaint, holding that the lower courts erred.Plaintiff and Defendant entered into a contract for the renovation of a residence. Plaintiff later filed a complaint alleging breach of contract and violation of the Tennessee Consumer Protection Act. Defendant filed an amended countercomplaint asserting breach of contract. The trial court dismissed all of Plaintiff's claims and then dismissed the countercomplaint. On appeal, Plaintiff challenged the attorney fee and costs award granted by the trial court. The court of appeals affirmed. The Supreme Court vacated the trial court's award of attorney fees and costs, holding that the fees and costs recoverable by Plaintiff in connection with the dismissal of Defendant’s breach of contract claim are not limited to those incurred after the amended countercomplaint was actually filed. View "Donovan v. Hastings" on Justia Law

The Supreme Court held that the economic loss doctrine applies when a fraud claim seeks recovery of only economic losses and is premised solely on nondisclosures or misrepresentations about the quality of goods that are the subject of a contract between sophisticated commercial parties.Plaintiff sued Defendants alleging breach of express and implied warranties, breach of contract, negligent misrepresentation, fraud, and a Tennessee Consumer Protection Act (TCPA) claim. The trial court granted Defendants summary judgment on the breach of contract, breach of warranty, and negligent misrepresentation claims. After a trial, the jury returned a verdict for Plaintiff on the fraud and TCPA claims and awarded compensatory and punitive damages. The trial court entered judgment on the jury's verdicts and awarded Plaintiff attorney's fees. On appeal, the court of appeals ruled in favor of Defendants and against Plaintiff, concluding that the economic loss doctrine barred the fraud claim and that the claim under the TCPA was barred as a matter of law. The Supreme Court set aside Plaintiff's award of attorney's fees and costs based on the TCPA and otherwise affirmed, holding that because Plaintiff's TCPA claim failed as a matter of law, the award of attorney's fees and costs under the TCPA could not stand. View "Milan Supply Chain Solutions, Inc. v. Navistar, Inc." on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the trial court's judgment dismissing Plaintiff's second lawsuit, holding that the doctrine of res judicata did not bar the lawsuit.Plaintiff originally filed suit against Defendant in the Circuit Court for Shelby County, but, unbeknownst to the parties, the trial court sua sponte dismissed the lawsuit for failure to prosecute. Ten months later, Plaintiff learned of the dismissal and filed a motion to set aside the dismissal. The trial court denied the motion but entered an order stating that the dismissal did not bar Plaintiff from refiling its lawsuit. When Plaintiff subsequently refiled its lawsuit, the trial court granted Defendant's motion to dismiss based on the doctrine of res judicata. The court of appeals affirmed. The Supreme Court reversed the decision of the court of appeals and vacated the judgment of the trial court, holding that the involuntary dismissal of the first suit for failure to prosecute did not operate as an adjudication on the merits, and therefore, the present lawsuit was not barred by the doctrine of res judicata. View "Regions Bank v. Prager" on Justia Law

In this case involving the correct interpretation of provisions in the Prompt Pay Act, Tenn. Code Ann. 66-34-101 to -704, relating to retainage withheld on construction projects, the Supreme Court held that the $300 per day penalty is assessed each day retaining is not deposited in a statutorily-compliant escrow account.The Act requires the party withholding retain age to deposit the funds into a separate, interest-bearing escrow account, and failure to do so results in a $300 per day penalty. Here, Subcontractor's retainage was not placed into an interest-bearing escrow account, and the retainage was not timely remitted to Contractor. Three years after completing its contractual duties, Subcontractor sued Contractor for unpaid retainage plus amounts due under the Act. Thereafter, Contractor tendered the retainage. At issue was the statutory penalty. The trial court concluded that Subcontractor's claim under the Act was barred by Tenn. Code Ann.'s one-year statute of limitations. The court of appeals affirmed. The Supreme Court reversed, holding that while Subcontractor's claim for the statutory penalty was subject to the one-year statute of limitations, if Subcontractor can establish that Contractor was required to deposit the retainage into an escrow account, Subcontractor was not precluded from recovering the penalty assessed each day during the period commencing one year before the complaint was filed. View "Snake Steel, Inc. v. Holladay Construction Group, LLC" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the trial court's dismissal of Plaintiffs' action seeking a declaratory judgment concerning the rights and obligations of the parties under a 2001 contract, holding that the court of appeals erred in concluding that dismissal was appropriate on the grounds that the complaint was barred by the doctrine of res judicata.In a previously filed action, Plaintiffs sought similar relief, but the case was dismissed for failure to exhaust administrative remedies. In the instant case, the trial court granted Defendants' motions to dismiss, finding that Plaintiffs lacked standing. The court of appeals affirmed on other grounds, concluding that res judicata barred the complaint and, as such, declined to address the standing issue. The Supreme Court reversed, holding that dismissal of the previous case did not constitute an adjudication on the merits for purposes of res judicata. The Court then remanded the case to the court of appeals for consideration of the standing issue. View "Elvis Presley Enterprises, Inc. v. City of Memphis" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the chancery court dismissing this complaint against a Texas company for lack of personal jurisdiction, holding that the exercise of specific personal jurisdiction was constitutionally permissible.The Texas company contracted with a Tennessee civil engineering company for services related to the potential construction of a railcar repair facility in Texas. When the Texas company failed to pay in full, the Tennessee company filed a breach of contract action in Tennessee. The chancery court dismissed the complaint, concluding that the Texas company lacked the minimum contacts necessary for the exercise of personal jurisdiction and that requiring the Texas company to litigate in Tennessee would be unreasonable and unfair. The court of appeals reversed. The Supreme Court affirmed, holding (1) the Tennessee company established a prima facie case for the valid exercise of personal jurisdiction over the Texas company; and (2) the exercise of jurisdiction was fair and reasonable. View "Crouch Railway Consulting, LLC v. LS Energy Fabrication, LLC" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the decision of the trial court granting summary judgment to an architect firm seeking to recover its design fees from a development company, holding that disputed issued of material fact existed that precluded summary judgment.Plaintiff, the architect firm, designed a condominium project for Defendant, the development company. Defendant was not able to pay Plaintiff under the contract, and as a result, Plaintiff's project agreed to accept a condominium in the project instead of a fee. Defendant did not fulfill the agreement. Thereafter, Plaintiff filed a mechanic's lien for its unpaid fee under the contract and filed suit to enforce the lien. The trial court granted summary judgment to Plaintiff, concluding that there was insufficient evidence that the parties intended a novation by substituting the agreement to convey a condominium for the contract. The court of appeals affirmed. The Supreme Court reversed, holding that summary judgment was improperly granted because disputed questions of material fact existed about whether Plaintiff and Defendant intended a novation when they executed the agreement for the condominium. View "TWB Architects, Inc. v. Braxton, LLC" on Justia Law