Justia Tennessee Supreme Court Opinion Summaries

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 in this interpleader action reversing the judgment of the probate court denying a motion for the probate judge's recusal in this interpleader action, holding that the probate judge's denial of the recusal motion was appropriate in this case.Before his election to the bench, the probate judge at issue served as an expert witness in an earlier case involving one of the defendants. Based on expert opinions the judge expressed in the prior case that defendant moved for the judge's recusal. The probate court denied the motion, but the court of appeals reversed. The Supreme Court reversed and reinstated the probate judge's judgment denying the recusal motion, holding that a person of ordinary prudence in the probate judge's position would not find a reasonable basis for questioning his rationality. View "Adams v. Dunavant" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the trial court granting Defendant's motion to dismiss Plaintiff's vicarious liability claims under the common-law rule, holding that Tennessee's Health Care Liability Act necessarily implied an intent to abrogate the common-law rule under the circumstances of this case. Plaintiff brought this action against Defendant-hospital alleging that Defendant, either directly or vicariously through its employees and agents, negligently caused the death of Sheila Warren. The trial court granted Defendant's motion to dismiss, concluding that the vicarious liability claims fell within the operation-of-law exception and thus were subject to dismissal. The court of appeals reversed, holding that the Act and the common law conflicted, and therefore, the provisions of the Act prevailed. The Supreme Court affirmed, holding that the operation-of-law exception did not bar Plaintiff's claims. View "Ultsch v. HTI Memorial Hospital Corp." on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the order of the trial court granting Defendant's motion for summary judgment under the common-law rule governing vicarious liability claims, holding that Tennessee's Health Care Liability Act necessarily implied an intent to abrogate the common-law rule under the circumstances of this case.Plaintiff-patient sued Defendant-hospital alleging that Defendant, acting through its employees or agents, negligently provided medical treatment to her. Defendant moved for summary judgment, arguing that the claims were barred under common law. The trial court granted the motion, concluding that the vicarious liability claims fell within the operation-of-law exception and were therefore subject to dismissal. The court of appeals reversed, concluding that the claims were timely under the Act and that, given the conflict between the Act and the common law, the provisions of the Act prevailed. The Supreme Court affirmed, holding that the court of appeals correctly reversed the trial court's summary judgment in this case. View "Gardner v. Saint Thomas Midtown Hospital" on Justia Law

The Supreme Court reversed the decision of the court of criminal appeals reverting Defendant's aggravated robbery convictions to a classification lower due to the absence of a gang enhancement, holding that the court of criminal appeals erred in its decision.Defendant was arrested for aggravated robbery as to four individuals. The indictment contained four alternative counts each of aggravated robbery against four victims and four corresponding counts of criminal gang offense enhancement and alleged that Defendant was a "Crips" gang member. A jury convicted Defendant as charged. On appeal, Defendant argued that the evidence was insufficient to support his gang enhancement conviction. The court of appeals agreed. The Supreme Court reversed, holding (1) the gang enhancement statute does not require the State to specify in the indictment a criminal defendant's gang subset nor that the defendant is in the same gang subset as the individuals whose criminal activity establishes the gang's pattern of criminal gang activity; and (2) Defendant waived all other issues raised on appeal. View "State v. Shackleford" on Justia Law

The Supreme Court affirmed the judgment of the post-conviction court denying Petitioner's petition for post-conviction relief, holding that the provisions of Tenn. Sup. Ct. R. 13 are constitutional as applied, that Petitioner was not unconstitutionally denied appellate review of the denial of his request for expert funds, and that Petitioner was not deprived of a full and fair post-conviction hearing.Petitioner requested funds under Rule 13 to hire expert witnesses to assist in his post-conviction proceedings and, as to the four instances at issue on appeal, the post-conviction court authorized the funds. The Director of the Administrative Office of the Courts and the Chief Justice, however, either reduced the requested amount or denied approval of the funds. Petitioner continued without assistance of the witnesses, and was denied post-conviction relief. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the provisions of Rule 13 for prior approval review are constitutional as applied; (2) Petitioner was not unconstitutionally denied appellate review of the post-conviction court's denial of his expert funds request; and (3) Petitioner was not deprived of a fair post-conviction hearing due to the denial of expert funds. View "Dotson v. State" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the trial court's summary judgment to the three named state official defendants in this complaint seeking a temporary injunction related to the August 6, 2020 election, holding that Plaintiff was required to comply with both Tenn. Code Ann. 2-19-143(3) and Tenn. Code Ann. 40-29-202 before he could be re-enfranchised.Plaintiff, a Tennessee resident since 2018, was convicted in 1986 of involuntary manslaughter in Virginia. In 2020, the governor of Virginia granted Plaintiff clemency, thus reinstating his right to vote in Virginia. Later that year, Plaintiff attempted to register to vote in Grainger County, Tennessee but was denied. Plaintiff brought this lawsuit arguing that Tenn. Code Ann. 2-19-143(3) requires the state to re-enfranchise persons convicted of infamous crimes out of state when the governor or the appropriate authority of such other state restores that person's rights of citizenship. The chancery court granted summary judgment for Defendants, and the court of appeals affirmed. The Supreme Court affirmed, holding that, to regain the right of suffrage in Tennessee, Plaintiff and other similarly situated individuals must comply with both Tenn. Code Ann. 2-19-143(3) and the additional requirements set forth in Tenn. Code Ann. 40-29-202. View "Falls v. Goins" on Justia Law

The Supreme Court reversed the decision of the court of criminal appeals dismissing Defendant's appeal from the trial court's order for restitution and vacated the restitution order itself, holding that the restitution order was a final order but that the trial court erred by failing to consider Defendant's ability to pay in setting the amount of restitution.Defendant pleaded guilty to driving under the influence and leaving the scene of an accident. Defendant was later arrested for driving on a revoked license. After a hearing, the trial court revoked Defendant's probation, ordered him to serve the remainder of his sentence in confinement, and ordered restitution in the amount of $30,491. The court of criminal appeals dismissed Defendant's ensuing appeal from the restitution order, concluding that it was not a final order because it did not contain payment terms or schedule. The Supreme Court reversed the court of criminal appeals and vacated the restitution order, holding (1) because the order resolved all the issues in this case it was a final order under Tenn. R. App. P. 3; but (2) in setting the amount of restitution, the trial court erred by failing to consider Defendant's financial resources and ability to pay restitution. View "State v. Gevedon" on Justia Law

The Supreme Court reversed the judgment of the court of criminal appeals ruling that the restitution order at issue on appeal was not a final and appealable order under Tenn. R. App. P. 3, holding that a criminal restitution order is final and appealable when it directs a defendant to pay a set amount of restitution without payment terms.Defendant pleaded guilty to burglary and theft. As a condition of his probation, Defendant was ordered to pay restitution in the amount of $5,500 during his supervision. Defendant appealed the restitution order, but the court of criminal appeals dismissed the appeal for lack of jurisdiction, concluding that the restitution order was not a final order because it failed to include either payment terms or a payment schedule. The Supreme Court reversed and affirmed the trial court's judgment, holding (1) the restitution order resolved all issues and was a final order under Rule 3; and (2) the trial court did not err by ordering Defendant to pay $5,5000 in restitution over his two-and-a-half-year probationary period. View "State v. Cavin" on Justia Law

The Supreme Court held that a reimbursement cap imposed by the Tennessee Department of Finance and Administration's Division of TennCare, the state agency tasked with administering the federal Medicaid program in Tennessee, was a "rule" within the meaning of the Uniform Administrative Procedures Act that should have been promulgated through the notice-and-comment process.Emergency Medical Care Facilities, P.C., a corporation compromised of private healthcare professionals who provide emergency-department services to TennCare enrollees, brought this action against TennCare alleging that TennCare's decision to impose a $50 cap on the amount that Emergency Medical and other healthcare professionals could recover from TennCare for certain treatment provided to TennCare enrollees was a rule and that TennCare violated the Tennessee Uniform Administrative Procedures act (UAPA) by implementing the cap without rulemaking. The chancery court granted summary judgment in favor of Emergency Medical. The court of appeals reversed, concluding that the $50 cap fell within the so-called "internal-management exception" to the UAPA. The Supreme Court reversed, holding that the $50 cap was a rule under the UAPA and should have been promulgated through notice-and-comment rulemaking. View "Emergency Medical Care Facilities, P.C. v. Division of Tenncare" on Justia Law