Justia Tennessee Supreme Court Opinion Summaries

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

Ms. Sokolosky pleaded guilty to two misdemeanors and received consecutive 11-month, 29-day sentences, which were suspended for supervised probation. In February 2020, an arrest warrant was issued for her alleged probation violations, including not reporting and not making scheduled payments. She was taken into custody in April 2022 and filed a motion to dismiss the warrant, arguing that the records were untrustworthy due to unethical practices by the private probation company. The trial court denied her motion, found her in violation of probation, and extended her supervision. She appealed the revocation order and the denial of her motion to dismiss.The Court of Criminal Appeals dismissed her appeal as moot, reasoning that since her sentence had expired and she was no longer in custody, there was no active controversy to resolve. The court found that the case no longer served as a means to provide judicial relief and distinguished it from State v. Rodgers, which involved the Juvenile Post-Commitment Act.The Supreme Court of Tennessee reviewed the case and disagreed with the Court of Criminal Appeals. The Supreme Court held that Ms. Sokolosky’s appeal was not moot because the probation violation could have adverse consequences even after the completion of her sentence, such as affecting future sentencing or bond decisions. The court cited State v. Rodgers, which held that probation violations could have subsequent adverse effects, thus maintaining a genuine and existing controversy. The Supreme Court reversed the decision of the Court of Criminal Appeals and remanded the case for consideration on the merits. View "State v. Sokolosky" on Justia Law

In 1987, Pervis Payne was convicted of two counts of first-degree murder and one count of assault with intent to commit first-degree murder, receiving two death sentences and a thirty-year imprisonment term. The court ordered the sentences to be served consecutively, anticipating potential future commutation of the death sentences to life sentences. Decades later, following a legal pathway established by the Tennessee legislature, Payne was adjudicated intellectually disabled, leading to the vacating of his death sentences and their replacement with life sentences. The trial court also ordered that Payne’s sentences be served concurrently, making him eligible for parole in 2026.The Shelby County Criminal Court adjudicated Payne intellectually disabled and vacated his death sentences, substituting them with life sentences. The court also revisited the consecutive sentencing determination and ordered the sentences to be served concurrently. The State appealed, and the Court of Criminal Appeals affirmed the trial court’s decision, holding that the trial court had discretion to consider the manner of service of the sentences after vacating the death penalty.The Supreme Court of Tennessee reviewed the case and held that the trial court lacked jurisdiction to realign Payne’s sentences. The court affirmed the modification of Payne’s death sentences to life imprisonment but vacated the part of the trial court’s judgment that ordered the sentences to be served concurrently. The court emphasized that once a criminal judgment becomes final, it may not be modified unless a statute or rule authorizes its modification. The court remanded the case to the trial court for further proceedings consistent with its opinion. View "State of Tennessee v. Payne" on Justia Law

Petitioner Dudley King and eight other individuals consigned their recreational vehicles (RVs) to Music City RV, LLC (MCRV), an RV dealer, for sale. On August 28, 2008, an involuntary Chapter 7 bankruptcy petition was filed against MCRV in the United States Bankruptcy Court for the Middle District of Tennessee. The issue before the bankruptcy court was whether the consigned RVs were part of the bankruptcy estate. The parties stipulated that MCRV was not primarily engaged in selling consigned vehicles, was a merchant under UCC § 9-102(20), and performed the services of a consignee. None of the consignors filed a UCC-1 financing statement.The Bankruptcy Trustee argued that the consigned RVs were governed by Article 2 of the Uniform Commercial Code (UCC) and were subordinate to the rights of perfected lien creditors, including the Trustee. Mr. King contended that the consignment was a true consignment of "consumer goods" and not a sale, thus not covered by the UCC, and the RVs should not be part of the estate. The bankruptcy court certified a question to the Supreme Court of Tennessee regarding whether such a consignment is covered under Tennessee Code Annotated section 47-2-326.The Supreme Court of Tennessee reviewed the statutory language and the Official Comments to the UCC. The court concluded that the 2001 amendment to Tennessee Code Annotated section 47-2-326 removed consignment transactions from the scope of Article 2. The court held that the consignment of an RV by a consumer to a Tennessee RV dealer for the purpose of selling the RV to a third person is not covered under section 47-2-326 of the UCC as adopted in Tennessee. The court assessed the costs of the appeal to the respondent, Robert H. Waldschmidt, Trustee. View "State of Tennessee v. Brown" on Justia Law

The case involves a healthcare liability action filed by the plaintiff, Payton Castillo, against CHI Memorial Hospital and other entities and physicians, alleging negligence in the care provided to her husband, who died shortly after being discharged from the hospital's emergency room. The defendants sought a protective order based on the quality improvement committee (QIC) privilege under Tennessee Code Annotated section 68-11-272 to prevent inquiry into a meeting held by the hospital and the decedent's family. The trial court denied the defendants' motion.The Hamilton County Circuit Court initially reviewed the case and denied the defendants' motion for a protective order, finding that statements made during the meeting were not protected by the QIC privilege. The defendants appealed, and the Court of Appeals affirmed the trial court's decision, concluding that the statements made in the meeting were not protected by the QIC privilege.The Supreme Court of Tennessee reviewed the case and held that the QIC privilege applied to statements made during the meeting that were based on information obtained during the QIC process. However, the court found that Memorial waived the privilege when hospital management voluntarily disclosed the privileged information during the meeting with Mrs. Castillo. The court affirmed the judgment of the Court of Appeals on separate grounds and remanded the case to the trial court for further proceedings consistent with its opinion. View "Castillo v. Rex" on Justia Law

Vanessa Turner (formerly Vanessa Colley) and John S. Colley, III were divorced in 2012, with a marital dissolution agreement (MDA) and a permanent parenting plan incorporated into the final decree. Post-divorce, John filed a petition to terminate his transitional alimony obligation, alleging Vanessa was cohabiting with her fiancé. Vanessa defended the alimony award, and after extensive litigation, John nonsuited his petition before it was adjudicated on the merits.The Circuit Court for Davidson County awarded Vanessa $16,500 in attorney fees, finding it reasonably necessary for her to defend the alimony award. John appealed, and the Court of Appeals reversed, holding that neither party was a "prevailing party" under the MDA or Tennessee Code Annotated section 36-5-103(c) because the petition was nonsuited before a decision on the merits.The Supreme Court of Tennessee reviewed the case and held that Vanessa was the prevailing party under both the MDA and section 36-5-103(c). The Court reasoned that the MDA's language entitled Vanessa to attorney fees as the prevailing party because she successfully defended the alimony award, achieving her objective of maintaining the status quo. The Court also held that under section 36-5-103(c), a party defending against a petition to alter or modify an alimony award can be considered a prevailing party even if the petition is nonsuited before a decision on the merits.The Supreme Court reversed the Court of Appeals' decision, affirmed the trial court's award of attorney fees to Vanessa, and awarded her attorney fees on appeal. The case was remanded to the trial court to determine the amount of reasonable attorney fees for the appeals. View "Colley v. Colley" on Justia Law

In 2014, Emergency Medical Care Facilities, P.C. (EMCF) filed a putative class action against BlueCross BlueShield of Tennessee, Inc. (BCBST), alleging breach of contract due to a cap on certain payments for medical services. The trial court denied class certification, and the Court of Appeals affirmed. EMCF then voluntarily nonsuited its claims. After a favorable ruling in a separate lawsuit against TennCare, EMCF refiled its case against BCBST, again seeking class certification.The trial court held that collateral estoppel precluded relitigation of class certification, but the Court of Appeals reversed, stating that the prior class certification denial was not final for collateral estoppel purposes because the case had been voluntarily nonsuited.The Supreme Court of Tennessee reviewed the case to determine whether the prior denial of class certification, affirmed on appeal, was entitled to preclusive effect. The Court held that the trial court's and appellate court's decisions denying class certification in the earlier case were final and binding for purposes of collateral estoppel. The Court reasoned that the class certification issue had been fully litigated and decided, and the decision was subject to appeal, which EMCF did not pursue further. Therefore, EMCF was precluded from relitigating the class certification issue in the refiled case.The Supreme Court of Tennessee reversed the Court of Appeals' decision and remanded the case to the trial court, reinstating the order striking the class action allegations against BCBST and VSHP. The Court emphasized that the denial of class certification, affirmed on appeal, was sufficiently final to warrant preclusive effect, preventing EMCF from seeking a do-over on class certification. View "Emergency Medical Care Facilities, P.C. v. BlueCross BlueShield of Tennessee, Inc." on Justia Law