Justia Tennessee Supreme Court Opinion Summaries

Jo Carol Edwards was employed as a truck driver by Peoplease, LLC. On August 14, 2020, while working, she was involved in a motor vehicle accident that caused her knees to strike the dashboard, resulting in knee pain and injuries. Ms. Edwards was subsequently diagnosed with severe, pre-existing arthritis in both knees. However, medical experts disagreed on whether her need for knee replacement surgery and resulting disability were caused by an aggravation of her pre-existing condition due to the work accident or were solely attributable to the underlying arthritis. Ms. Edwards claimed workers’ compensation benefits for her knee injuries, arguing that the accident aggravated her arthritis and led to her symptoms and need for surgery.The Court of Workers’ Compensation Claims credited Ms. Edwards’ testimony that she was asymptomatic prior to the accident and found that her work-related accident aggravated her pre-existing arthritis, resulting in compensable knee injuries. The court ordered Peoplease to pay for her medical expenses, disability benefits, and related costs. On interlocutory appeal, the Workers’ Compensation Appeals Board partially affirmed but ultimately reversed the award on remand, finding that Ms. Edwards failed to overcome the presumption in favor of her treating physician’s opinion that the accident was not the primary cause of her need for surgery and disability.The Supreme Court of Tennessee reviewed the case. It clarified that factual findings in workers’ compensation cases are reviewed de novo on the record with a presumption of correctness unless the preponderance of the evidence indicates otherwise, regardless of whether the findings are based on live or deposition testimony. The court further held that an aggravation injury under Tennessee law does not require a permanent change to be compensable; it is sufficient if the aggravation primarily arises out of employment and contributes more than fifty percent to the need for medical treatment or disability. Applying this standard, the Supreme Court reversed the Appeals Board’s decision and reinstated the Trial Court’s award of benefits to Ms. Edwards. View "Edwards v. Peoplease, LLC" on Justia Law

Brian Coblentz was employed as a sales representative for Stanley National Hardware, a vendor supplying hardware products to retail stores, including Tractor Supply Company. His duties involved visiting Tractor Supply stores, checking inventory, placing orders, and maintaining the appearance of Stanley National product displays. During a visit to a Fayetteville, Tennessee Tractor Supply store, Coblentz was injured when a barn door track from a Stanley National display fell on him. Stanley National paid him workers’ compensation benefits. Coblentz and his wife then sued Tractor Supply, alleging negligence in maintaining the display and failing to warn about potential hazards.The Circuit Court for Lincoln County granted summary judgment for Tractor Supply. It found Tractor Supply to be Coblentz’s “statutory employer” under Tennessee Code Annotated section 50-6-113(a), reasoning that Coblentz’s work was part of Tractor Supply’s regular business. This classification shielded Tractor Supply from tort liability under the exclusive remedy provision of Tennessee’s workers’ compensation statutes. The Tennessee Court of Appeals affirmed, applying the same statutory employer analysis. However, one judge dissented, arguing that the relationship between Stanley National and Tractor Supply was purely vendor-vendee, not principal-subcontractor, and thus should not invoke workers’ compensation protections.On appeal, the Supreme Court of Tennessee reversed the lower courts. It held that the term “subcontractor” in section 50-6-113(a) refers to entities performing labor or services, and does not encompass a pure vendor-vendee relationship involving only the sale and ancillary delivery of goods. Applying a “predominant purpose” test, the Court found the primary purpose of the arrangement was merchandise sales, with additional services being incidental. Therefore, Tractor Supply is not Coblentz’s statutory employer and is not protected by the exclusive remedy provision. The case was remanded for further proceedings. View "Coblentz v. Tractor Supply Company" on Justia Law

After the 2020 census, Tennessee’s General Assembly redrew the state House and Senate legislative maps. Two voters, Gary Wygant and Francie Hunt, challenged these new maps. Wygant, a resident of Gibson County, argued the House map violated the state constitution by splitting more counties than necessary to comply with federal law. Hunt, a Davidson County voter, asserted the Senate map violated the state constitution’s requirement that multi-district counties’ Senate districts be consecutively numbered, because Davidson County’s new districts were not.The case was initially heard by a three-judge panel in the Davidson County Chancery Court. At trial, the panel allowed only Wygant’s district-specific challenge (focused on Gibson County) and Hunt’s claim regarding Davidson County’s Senate districts to proceed. The court found Wygant had standing only as to the Gibson County split and dismissed his broader challenge. The court ruled that the House map was constitutional, finding the state’s actions justified given federal requirements. However, the panel found Hunt had standing and declared the Senate map unconstitutional due to the misnumbering of Davidson County’s districts.The Supreme Court of Tennessee reviewed the case. It held that Wygant had standing only to challenge the split of Gibson County, not the entire House map. The Court concluded that although Wygant demonstrated it was possible to draw a map that split fewer counties, he did not prove the Gibson County split was unnecessary to comply with federal law or lacked a rational or legitimate basis. The Court further held that Hunt did not suffer an injury in fact from the Senate map’s numbering, and therefore lacked standing. As a result, the Court affirmed the trial court’s rejection of Wygant’s district-specific challenge, reversed the finding that Hunt had standing, vacated the judgment declaring the Senate map unconstitutional, and remanded for further proceedings. View "Wygant v. Lee" on Justia Law

Alan Cartwright was the beneficiary of a family trust managed by his sister, Alice Garner, and her husband, Alan Garner. Over more than a decade, Cartwright, represented by attorneys Jerry Mitchell and later his son Justin Mitchell, brought six lawsuits against the Garners challenging their administration of the trust. All of these lawsuits were ultimately resolved in favor of the Garners. After the trust litigation concluded, Cartwright, dissatisfied with his legal representation, sued the Mitchells for legal malpractice and fraudulent concealment. The Garners also sued the Mitchells and their law firms under the tort-of-another doctrine, seeking to recover attorney’s fees, costs, and expenses incurred during the trust litigation.In the Circuit Court for Shelby County, the Mitchells moved to dismiss the Garners’ suit under the Tennessee Public Participation Act (TPPA), arguing that the claims were filed in response to their exercise of the right to petition. The trial court denied the motion, reasoning that the TPPA did not protect attorneys alleged to have acted inconsistently with their client’s interests. On appeal, the Tennessee Court of Appeals reversed, holding that the Mitchells had met their initial burden under the TPPA by showing the Garners’ suit related to the underlying trust lawsuits.The Supreme Court of Tennessee reviewed the case and held that, under the TPPA, an attorney filing a lawsuit on behalf of a client does not personally exercise the right to petition; rather, the attorney facilitates the client’s exercise of that right. Therefore, the Mitchells failed to demonstrate that the Garners’ suit was filed in response to the Mitchells’ own exercise of the right to petition. The Supreme Court of Tennessee reversed the Court of Appeals’ decision and remanded the case for further proceedings, denying the Mitchells’ petition for dismissal under the TPPA. View "Garner v. Thomason, Hendrix, Harvey, Johnson & Mitchell" on Justia Law

A beneficiary of a family trust, dissatisfied with the outcome of multiple lawsuits against his sister and her husband concerning trust administration, brought claims for legal malpractice and fraudulent concealment against the lawyers who had represented him in those actions. He alleged that the lawyers filed nonmeritorious lawsuits primarily to obtain a contingency fee and failed to keep him informed, ultimately leaving him responsible for attorney’s fees when the cases were resolved against him.The lawyers and their associated law firms responded by seeking dismissal under the Tennessee Public Participation Act (TPPA), arguing that the malpractice suit was filed in response to their “exercise of the right to petition”—specifically, the act of filing lawsuits on the beneficiary’s behalf. The Circuit Court for Shelby County denied this petition, holding that an attorney sued by a former client for malpractice cannot establish that the suit was in response to the attorney’s own exercise of the right to petition. The Court of Appeals reversed, finding that legal malpractice claims are not categorically excluded from the TPPA and that, in this instance, the lawyers had made a prima facie showing that the complaint related to their exercise of the right to petition.The Supreme Court of Tennessee granted permission to appeal and held that, even assuming filing a lawsuit is an “exercise of the right to petition” under the TPPA, an attorney who files suit on behalf of a client does not personally exercise that right—the attorney merely facilitates the client’s exercise of it. Thus, the lawyers could not show that the malpractice and concealment suit was brought in response to their own exercise of the right to petition. The Supreme Court of Tennessee reversed the Court of Appeals, denied the lawyers’ TPPA petition, and remanded the case for further proceedings. View "Cartwright v. Thomason Hendrix, P.C." on Justia Law

An employee working as a practice manager at a healthcare facility in Cleveland, Tennessee, claimed that she contracted COVID-19 in December 2020 through workplace exposure to infected patients and coworkers. She sought workers’ compensation benefits, alleging disabling lung injuries and long-term complications as a result. Initially, the employer paid temporary disability benefits but later denied her request for total disability, relying on the opinion of a pulmonologist who concluded that her exposure to the virus could not be attributed primarily to her workplace given widespread community transmission.The Court of Workers’ Compensation Claims considered the employer’s motion for summary judgment, supported by the pulmonologist’s opinion that workplace exposure could not be established as the primary cause of the illness. The court excluded certain medical evidence offered by the employee and denied her request for a continuance to obtain a new medical expert. It subsequently granted summary judgment for the employer, finding that the employee had failed to present expert medical evidence of causation, an essential element of her claim.On appeal, the Workers’ Compensation Appeals Board affirmed, holding that the employee’s challenge to the denial of a continuance was untimely and that summary judgment was appropriate due to her lack of expert proof on medical causation. The Supreme Court of Tennessee Special Workers’ Compensation Appeals Panel reviewed the case and affirmed the Appeals Board’s judgment. The court held that, where an employee fails to provide expert medical evidence establishing that her injury arose primarily out of her employment, summary judgment for the employer is warranted. The court also found no reversible error in the handling of procedural issues and clarified that earlier case law regarding employer filing obligations did not preclude the employer’s defenses in this context. View "Graham v. CHI Memorial Healthcare System" on Justia Law

A married couple owned all shares of a corporation that operated a boat dealership and served as an authorized dealer for a boat manufacturer. After the manufacturer ended its relationship with the dealership, the business failed, leading to foreclosure on its property and the couple’s personal bankruptcies. The couple then sued the manufacturer for intentional misrepresentation, fraudulent concealment, and promissory fraud, alleging that the manufacturer’s conduct caused the loss of their business and personal assets. A jury awarded them $900,000 in compensatory damages for the loss of equity in the dealership’s real property.Following the verdict, the manufacturer filed post-trial motions and, for the first time at the hearing, challenged the couple’s standing, arguing that the damages related to property owned by the corporation, not the individuals, and that any claims should have been brought derivatively on behalf of the corporation. The Circuit Court for Loudon County agreed, finding the couple lacked “statutory standing” and dismissing the suit for lack of subject matter jurisdiction. The Tennessee Court of Appeals reversed, holding that shareholder standing limitations are not jurisdictional and can be waived, and that the manufacturer had forfeited its challenge by raising it too late.The Supreme Court of Tennessee affirmed the Court of Appeals. It held that the couple had constitutional standing to bring their claims, as they alleged injury to their legal rights as shareholders. The Court further held that the trial court erred in applying statutory standing principles, since the claims were not brought as a derivative action. Instead, the issue implicated shareholder standing, which is non-jurisdictional and subject to forfeiture if not timely raised. The case was remanded for further proceedings. View "Houghton v. Malibu Boats, LLC" on Justia Law

A woman died after being treated at a hospital and left behind two minor children. Her mother took custody of the children following a juvenile court order that granted her authority over their care. The mother, acting as custodian, sent pre-suit notice to the health care providers she believed responsible for her daughter’s death, identifying herself as the “claimant authorizing the notice” but not mentioning the minor children. She later filed a wrongful death lawsuit, initially on her own behalf and on behalf of the children, but ultimately pursued the claim solely for the children.The Circuit Court for Anderson County first granted, then vacated, the defendants’ motions to dismiss, finding that the mother had substantially complied with the pre-suit notice requirements and that the omission of the children’s names did not prejudice the defendants. The court also found that while the children held the right to the claim, the mother was the claimant on their behalf. The Court of Appeals, however, reversed this decision, holding that the pre-suit notice was deficient because it failed to identify the children as claimants, and that this failure prejudiced the defendants. The appellate court did agree that the mother had standing to bring the suit on behalf of her grandchildren.The Supreme Court of Tennessee reviewed the case and reversed the Court of Appeals. The Court held that under Tennessee Code Annotated section 29-26-121(a)(2)(B), the “claimant authorizing the notice” is the person who asserts the right and formally approves giving pre-suit notice. Since the minor children could not act for themselves, their legal custodian was the proper person to authorize notice and file suit on their behalf. The Court concluded that the mother complied with the statutory pre-suit notice requirements and remanded the case to the circuit court. View "Denson ex rel. Denson v. Methodist Medical Center of Oak Ridge" on Justia Law

A firefighter with fifteen years of service applied for disability pension benefits from a municipal pension fund, claiming he was permanently disabled due to post-traumatic stress disorder (PTSD) resulting from several traumatic events encountered during his career. The pension fund’s Board of Trustees denied his application after a hearing, finding he did not meet the policy’s requirements for a mental health disability benefit, specifically the requirement that the traumatic events causing the disability be “unexpected” within the context of his regular duties.The applicant sought judicial review in the Chancery Court for Hamilton County, which reviewed the Board’s decision under Tennessee’s Uniform Administrative Procedures Act (UAPA). The trial court found the Board’s interpretation of the policy arbitrary and capricious, holding that the events were unexpected to the applicant and that the policy should be construed in favor of the employee. The trial court reversed the Board’s denial and awarded benefits. The Tennessee Court of Appeals affirmed, finding the policy ambiguous and applying a liberal construction doctrine to interpret the policy in favor of the applicant.On further appeal, the Supreme Court of Tennessee held that the term “unexpected” in the policy was not ambiguous and should be given its plain meaning. The Court concluded that the Board’s decision was supported by substantial and material evidence and was not arbitrary or capricious. The Court also held that the liberal construction doctrine did not apply because the policy was unambiguous. Accordingly, the Supreme Court of Tennessee reversed the judgments of the Court of Appeals and the trial court, reinstating the Board’s denial of disability benefits, and remanded the case for further proceedings consistent with its opinion. View "Long v. Chattanooga Fire and Police Pension Fund" on Justia Law

A police officer responded to a report of a car accident in a residential area during the early morning hours and found a vehicle partially in a yard, facing the wrong direction. The officer approached the vehicle and saw Ambreia Washington in the driver’s seat, with a handgun visible on the front passenger seat. After asking Washington to exit the vehicle, the officer inquired whether Washington was a convicted felon, to which Washington replied affirmatively. When Washington attempted to flee, the officer used a taser and placed him under arrest, seizing the handgun. Washington was indicted for unlawful possession of a firearm by a convicted felon and other charges.Washington moved to suppress both the handgun and his statement regarding his felony status. The Circuit Court for Madison County suppressed the statement due to a Miranda violation but denied the motion to suppress the handgun, finding it was properly seized under the plain view doctrine. At trial, Washington was convicted by a jury. On appeal, the Tennessee Court of Criminal Appeals affirmed the trial court’s rulings, concluding that the officer’s actions were justified under the community caretaking doctrine and that the seizure of the handgun was permissible under the plain view doctrine.The Supreme Court of Tennessee reviewed whether the officer’s warrantless seizure of the firearm was lawful. The court held that the seizure was constitutionally permissible under the plain view doctrine, even though the officer’s probable cause to seize the gun was based on Washington’s unwarned but voluntary admission of his felony status. The court clarified that such nontestimonial evidence derived from a voluntary but un-Mirandized statement need not be suppressed absent coercion. The judgment of the Court of Criminal Appeals was affirmed. View "State v. Washington" on Justia Law