Justia Tennessee Supreme Court Opinion Summaries

Three documents related to a criminal case in Davidson County were filed and sealed without a written order by the presiding judge, who subsequently recused herself. After the case was transferred to a new trial court, a news organization sought to intervene and unseal the documents, which included a motion for judicial disqualification and supporting affidavits. The documents were not listed on the public docket, and the clerk’s office explained that they were marked “Filed Under Seal” by the preparer, but no formal order authorized the seal.The Criminal Court for Davidson County allowed the news organization to intervene but denied its motion to unseal the documents. The trial court found that more compelling interests were at stake, including the risk of publishing unsupported claims, potential embarrassment or burden to involved persons, and possible delays or denials of due process. The court ordered that the documents remain sealed and later issued a separate order citing confidentiality under Supreme Court rules. The news organization then sought review in the Tennessee Court of Criminal Appeals, which denied both an extraordinary appeal and a writ of certiorari, concluding that interlocutory appeal was not available to media intervenors in criminal cases.The Supreme Court of Tennessee granted review to address the availability of interlocutory appeals for media intervenors and the standard for sealing judicial records. The court held that such appeals are available to media intervenors when judicial proceedings are closed or records are sealed. The court further ruled that sealing judicial records protected by the First Amendment requires a written order identifying a compelling interest and that the seal must be narrowly tailored. After conducting a de novo review, the court found no compelling interest justifying the seal and ordered the documents to be made public, reversing the Court of Criminal Appeals. View "State of Tennessee v. Johnson" on Justia Law

In February 1994, Tony Carruthers, along with James and Jonathan Montgomery, was involved in the murders of Marcellos Anderson, Delois Anderson, and Freddrick Tucker. The victims were killed and buried beneath a casket in a Memphis cemetery. The prosecution presented evidence at trial that Carruthers had planned the crimes in advance and discussed the murders with others. Multiple witnesses placed Carruthers at the scene, and there was testimony that he confessed to the murders. Carruthers was convicted of three counts of murder and sentenced to death. Over the years, he has repeatedly claimed innocence and sought relief through various post-conviction and habeas proceedings, including requests for DNA and fingerprint testing on evidence from the crime scene.After the Tennessee Supreme Court affirmed his convictions and sentences, Carruthers pursued post-conviction relief in state and federal courts, but these efforts were unsuccessful. He previously sought DNA testing under the Post-Conviction DNA Analysis Act of 2001 and the Post-Conviction Fingerprint Analysis Act of 2021, but the courts denied his motions, finding that the results would not have changed the outcome of his conviction or sentence. Most recently, less than two months before his scheduled execution, Carruthers filed a motion for last-minute DNA testing of fingernail scrapings and bindings from the victims. The post-conviction court denied the motion, finding he failed to meet the statutory criteria for DNA testing, and the Court of Criminal Appeals was set to review the case when the Tennessee Supreme Court assumed jurisdiction.The Supreme Court of Tennessee affirmed the post-conviction court’s judgment. The court held that Carruthers failed to meet the first and fourth statutory criteria under both the mandatory and discretionary provisions of the DNA Act: there was not a reasonable probability that favorable DNA results would have prevented his prosecution or conviction, and the motion appeared designed to unreasonably delay his execution. The court concluded there was no abuse of discretion in denying the motion for DNA testing. View "Carruthers v. State" on Justia Law

Cinda Haddon was injured in a motor vehicle collision when Ladarius Vanlier, who was uninsured, struck her vehicle. Haddon filed a lawsuit against Vanlier for negligence and, as allowed by Tennessee’s Uninsured Motorist Act, served process on her uninsured motorist insurer, Auto-Owners Insurance Company. Vanlier could not be served, so Haddon proceeded directly against Auto-Owners. The case went to a jury trial, which found Vanlier at fault and awarded Haddon $320,000 in damages for her personal injuries, including pain and suffering, loss of enjoyment of life, permanent injury, and medical expenses.After the jury’s award, Haddon requested prejudgment interest. The Circuit Court for Davidson County denied her request, reasoning that prejudgment interest is not available for personal injury actions under Tennessee law, even though equitable considerations would otherwise support such an award. Haddon appealed. The Court of Appeals for Tennessee reversed, holding that claims against an uninsured motorist carrier sound in contract, not tort, meaning the prohibition on prejudgment interest for personal injury actions did not apply. The Court of Appeals sent the case back to the trial court to determine the amount of prejudgment interest.The Supreme Court of Tennessee reviewed the case and concluded that the action’s gravamen was in personal injury, not contract. The Court determined that Haddon’s claim was based on the tortious conduct of Vanlier and sought damages for personal injuries, rather than any breach of contract by Auto-Owners. As prejudgment interest is not allowed in personal injury actions under Tennessee law, the Supreme Court of Tennessee reversed the Court of Appeals and reinstated the trial court’s judgment denying prejudgment interest. The holding is that prejudgment interest is not available in an action brought against a tortfeasor and defended by an uninsured motorist carrier when the claim’s gravamen is personal injury. View "Haddon v. Vanlier" on Justia Law

A Kentucky-based luxury car broker persuaded the owner of a Tennessee car dealership to wire over $80,000 for the purchase of a specific Mercedes vehicle. The broker, communicating through text messages and emails, sent an invoice and a bill of sale falsely representing ownership and authority to transfer the car. After receiving the funds, he neither delivered the vehicle nor returned the money. Instead, he spent portions of the funds on personal expenses, including a vacation. Despite multiple requests and promises to return the money, the broker did not fulfill his obligations.A Loudon County grand jury indicted the broker for theft of property over $60,000 under Tennessee law. The defendant moved to dismiss the indictment, arguing that Tennessee lacked territorial jurisdiction, but the Loudon County Criminal Court denied the motion. At trial, the defendant gave inconsistent testimony about his involvement. The jury found him guilty, and the trial court sentenced him to ten years, with part of the sentence to be served in prison and the remainder on probation, along with restitution. The defendant’s motion for a new trial was denied. On appeal, the Tennessee Court of Criminal Appeals affirmed the conviction, finding that territorial jurisdiction was proper because the crime was consummated in Tennessee and that the victim’s consent was ineffective because it was induced by deception.The Supreme Court of Tennessee reviewed the case and held that Tennessee courts had statutory territorial jurisdiction under Tennessee Code Annotated section 39-11-103(b) because the theft offense was consummated in Tennessee through electronic communications originating from Kentucky. The court also found that the evidence was sufficient to support the conviction, as the victim’s consent to transfer the funds was obtained through deception. The Supreme Court of Tennessee affirmed the judgment of the Court of Criminal Appeals. View "State of Tennessee v. Lacy" on Justia Law

In 2019, the governing body of a Tennessee county adopted a resolution regulating the operation and location of quarries and similar activities in unincorporated areas. The resolution prohibited quarries from being located within 5,000 feet of residences, schools, parks, and various other establishments. After purchasing property and leasing it for quarry operations, the plaintiffs were informed by the county mayor that their quarry violated this resolution and were asked to cease operations. The plaintiffs filed a declaratory judgment action, arguing that the resolution was void because it functioned as a zoning ordinance and was not enacted in compliance with statutory zoning procedures. The county, in response, maintained that the resolution was not a zoning ordinance but rather a proper exercise of its police powers.The case was first heard in the Chancery Court for Grundy County, which granted summary judgment in favor of the county. The court reasoned that, because the county did not have a comprehensive zoning plan, the resolution could not be considered tantamount to zoning and thus was not subject to the County Zoning Act’s requirements. The Tennessee Court of Appeals affirmed, but on different grounds. It held that the absence of a comprehensive zoning plan was not determinative but concluded that the resolution did not divide the county into districts and thus was not a zoning ordinance.The Supreme Court of Tennessee reviewed the case and reversed the lower courts. The Court held that the resolution was, in effect, a zoning ordinance because it divided the county into zones—prohibiting quarrying in certain areas based on proximity to designated establishments—and substantially affected land use. The Court found that the county failed to comply with the procedural requirements of the County Zoning Act, rendering the resolution unenforceable. The judgment was reversed, and the case was remanded for entry of summary judgment in favor of the plaintiffs. View "Tinsley Properties, LLC v. Grundy County, Tennessee" on Justia Law

Berkeley Research Group, LLC and Southern Advanced Materials, LLC entered into a contract in 2019 for consulting services, which included an arbitration clause specifying that any disputes would be resolved via arbitration in Philadelphia, Pennsylvania. After Southern allegedly failed to pay for Berkeley's services, the parties participated in arbitration administered by JAMS, with the arbitrator located in Philadelphia. The arbitration was conducted via Zoom, and the arbitrator ultimately awarded Berkeley $433,815.34. Berkeley then filed a petition in the Shelby County Chancery Court in Tennessee to confirm the arbitration award.The Shelby County Chancery Court denied Southern’s motion to dismiss, finding it had jurisdiction and confirming the award. Southern appealed, and the Tennessee Court of Appeals affirmed the trial court’s subject matter jurisdiction under Tennessee Code Annotated section 29-5-323 but reversed on personal jurisdiction grounds, holding that Southern lacked sufficient contacts with Tennessee. The appellate court remanded with orders to dismiss.The Supreme Court of Tennessee granted permission to appeal and reviewed whether Tennessee courts have subject matter jurisdiction to confirm an arbitration award where the agreement specified arbitration in another state. The Court held that, under the Uniform Arbitration Act (UAA), Tennessee courts only have subject matter jurisdiction to confirm arbitration awards when the agreement provides for arbitration in Tennessee. Because the parties’ contract required arbitration to occur in Pennsylvania and did not allow for arbitration in Tennessee, the Shelby County Chancery Court lacked subject matter jurisdiction. The Supreme Court of Tennessee vacated the judgments of both lower courts and dismissed Berkeley’s petition to confirm the award. The disposition by the Supreme Court of Tennessee was to vacate and dismiss for lack of subject matter jurisdiction. View "Berkeley Research Group, LLC v. Southern Advanced Materials, LLC" on Justia Law

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