Justia Tennessee Supreme Court Opinion Summaries

In 2023, the Tennessee General Assembly enacted a statute imposing a cap of twenty voting members on metropolitan councils, affecting the Metropolitan Government of Nashville and Davidson County, which had a forty-member council. Metro Nashville and several individual plaintiffs challenged the statute, arguing it violated the Local Legislation Clause and the Exemption Clause of the Tennessee Constitution. They sought declaratory and injunctive relief to prevent implementation of the law.The Chancery Court for Davidson County, sitting as a three-judge panel, held that the cap violated both constitutional provisions and issued a permanent injunction against enforcement. The panel found some claims moot due to expired compliance deadlines but concluded that the main cap provision remained justiciable. The Court of Appeals reversed, holding that the cap did not violate either clause and that the claims were not moot, except as to certain implementation provisions.After granting permission to appeal, the Supreme Court of Tennessee reviewed the case. During the proceedings, the General Assembly amended the statute, removing the implementation provisions and the language linking the cap to those provisions. The Supreme Court determined that these amendments rendered the Local Legislation Clause claim moot, as the alleged defect no longer existed. The Court vacated the Court of Appeals’ judgment on this issue and instructed the trial court to dismiss the claim.The Court further held that the Exemption Clause claim remained justiciable but, on the merits, concluded that the Exemption Clause only exempts consolidated governments from constitutional requirements regarding legislative bodies, not from statutory requirements imposed by the legislature. Therefore, the twenty-member cap does not violate the Exemption Clause. The Supreme Court of Tennessee affirmed the Court of Appeals’ judgment on this issue and remanded the case for further proceedings consistent with its opinion. View "Metropolitan Government of Nashville and Davidson County v. Lee" on Justia Law

A 2023 Tennessee law amended the structure and appointment process for the board of commissioners of the Metropolitan Nashville Airport Authority, reducing its board size and transferring most appointment powers to state officials. The changes applied only to the Nashville authority and not to any other airport authority in the state. The Metropolitan Government of Nashville and Davidson County filed suit, alleging that the new law violated specific provisions of the Tennessee Constitution, including the Local Legislation Clause and Anti-Ripper Clause.The Chancery Court for Davidson County, sitting as a three-judge panel, found that the law violated all three constitutional provisions alleged and enjoined its enforcement. The state defendants appealed and the Tennessee Court of Appeals affirmed the trial court in part, holding that the law violated the Local Legislation Clause, but reversed on the Law of the Land Clause. The Anti-Ripper Clause claim was not addressed by the appellate court. The state sought further review in the Supreme Court of Tennessee.While the case was pending before the Supreme Court of Tennessee, the General Assembly repealed and replaced the challenged provisions with new legislation that applied more broadly to multiple airport authorities. The Supreme Court of Tennessee held that these legislative changes rendered the case moot because the specific statutory provisions challenged were no longer in effect and could not reasonably be expected to recur. It found no basis to apply the voluntary cessation exception to mootness, as there was no evidence the legislature would reenact the specific challenged provisions. The Supreme Court vacated the lower courts’ judgments and remanded the case to the trial court with instructions to dismiss it as moot. View "Metropolitan Government of Nashville and Davidson County v. Lee" on Justia Law

During a 2021 sting operation in Monroe County, Tennessee, law enforcement posted an online advertisement for a fictitious escort who was purportedly 22 years old but, during text exchanges, identified herself as a 16-year-old. Anthony Cornelius Baylis responded to the ad and, after learning of the purported age, initially hesitated but then continued communicating. He encouraged the undercover officer, whom he believed to be a minor, to come to Knoxville for higher earnings and offered to be her “sponsor,” suggesting a trafficking relationship. Baylis arranged a meeting, brought payment, and was arrested after attempting to engage in sexual activity.Baylis was indicted by a Monroe County grand jury for trafficking for a commercial sex act under Tennessee Code Annotated section 39-13-309. At trial in the Circuit Court for Monroe County, the State proceeded solely on the trafficking charge. Baylis moved for a judgment of acquittal, arguing the State failed to prove the necessary elements of a “commercial sex act” because the officer was not a minor and there was no coercion or deception. The trial court denied the motion, and the jury convicted Baylis. The Court of Criminal Appeals affirmed the conviction, holding that the evidence was sufficient since Baylis intended to traffic someone he believed was a minor.The Supreme Court of Tennessee reviewed whether sufficient evidence supported Baylis’s conviction given statutory requirements. The Court held that section 39-13-309(a)(3) criminalizes attempting to traffic a law enforcement officer posing as a minor, regardless of actual age or the presence of coercion or deception. The Court found that a rational jury could conclude Baylis attempted to benefit from a commercial sex act with someone he believed to be a minor. The Supreme Court of Tennessee affirmed both Baylis’s conviction and the judgment of the Court of Criminal Appeals. View "State v. Baylis" on Justia Law

Jamesway Construction, Inc. was involved in a dispute with the Tennessee Department of Environment and Conservation (TDEC) regarding the alleged unauthorized filling of wetlands in Coffee County. After a citizen complaint and subsequent investigation, TDEC issued an order in 2018 assessing damages and penalties against Jamesway, alleging violations under the Water Quality Control Act. Jamesway contested these allegations in a contested case hearing before an administrative law judge. The judge found TDEC failed to prove its case regarding wetland filling and dismissed most damages but imposed a civil penalty for failing to obtain a stormwater permit.Following the initial administrative decision, TDEC appealed to the Board of Water Quality, Oil, and Gas. Jamesway moved to dismiss the appeal, arguing TDEC’s notice of appeal was untimely under the Uniform Administrative Procedures Act’s 15-day deadline, and the Board lacked subject matter jurisdiction. The administrative law judge denied the motion, finding a 30-day deadline applied. Jamesway then filed a petition for judicial review in the Davidson County Chancery Court, seeking immediate review of this procedural ruling. The chancery court, and subsequently the Tennessee Court of Appeals, ruled in Jamesway’s favor, finding the appeal deadline was 15 days and the Board lacked jurisdiction.The Supreme Court of Tennessee reviewed whether the chancery court had subject matter jurisdiction under Tennessee Code Annotated section 4-5-322(a)(1) to review a preliminary agency decision. The Court held that the chancery court lacked jurisdiction because Jamesway had not shown judicial review of the final agency decision would be inadequate. The Supreme Court vacated the judgments of the lower courts and remanded the case to the Board of Water Quality, Oil, and Gas for further proceedings, clarifying that only review of a final agency decision is permitted absent a showing of inadequate remedy. View "Jamesway Construction, Inc. v. Salyers" on Justia Law

An officer responded to an anonymous 911 call reporting a speeding red Chevrolet pickup on a state route in Tennessee, including its license plate number. The officer located a vehicle matching the description, followed it, and when the driver pulled into a store parking lot, the officer parked behind the truck, blocking it in. The driver, later identified as the defendant, admitted to drinking and speeding. The officer smelled alcohol, observed slurred speech, and found a handgun on the defendant during a pat-down. The defendant failed field sobriety tests and was arrested. He was indicted for driving under the influence, possession of a handgun while under the influence, possession of a handgun by a convicted felon, and violation of the implied consent law.The Criminal Court for Polk County denied the defendant’s motion to suppress evidence, finding that the officer seized the defendant by blocking his vehicle but had reasonable suspicion based on the corroborated anonymous tip. The defendant, pursuant to a plea agreement, pled guilty to DUI and handgun possession while reserving the right to appeal a certified question of law about the constitutionality of the seizure. The Court of Criminal Appeals dismissed the appeal, holding that the certified question failed to meet the requirements of Tennessee Rule of Criminal Procedure 37(b)(2) as interpreted by the Tennessee Supreme Court in State v. Preston, because it did not clearly identify the scope and limits of the legal issue reserved.The Supreme Court of Tennessee reviewed the case to determine if the procedural requirements for a certified question were met and whether to revise the certified-question procedure. The court held that appellate courts must consider the certified-question statement together with the record when determining if the scope and limits requirement is satisfied. Applying this standard, the court found that all requirements were met, reversed the dismissal, and remanded the case for consideration of the merits. View "State of Tennessee v. Burrell" on Justia Law

Police stopped a driver after learning his license was suspended and, upon smelling what they believed to be marijuana, searched his car and found a stolen handgun. The driver moved to suppress the handgun, arguing that officers could not distinguish the smell of illegal marijuana from legal hemp, which had been recently legalized in Tennessee. The trial court initially granted the motion but later denied it after reconsidering precedent stating that the smell of marijuana still provided probable cause for a vehicle search. The defendant then entered a conditional guilty plea, reserving a certified question of law for appeal concerning whether probable cause existed for the search under these circumstances.Upon review, the Tennessee Court of Criminal Appeals first affirmed the trial court, but after the Tennessee Supreme Court issued a decision in State v. Green clarifying the impact of hemp legalization on probable cause analysis, it remanded for reconsideration. On remand, the Court of Criminal Appeals dismissed the appeal, holding that the certified question was not “dispositive of the case” as required by Tennessee Rule of Criminal Procedure 37(b)(2)(A), because it did not address the totality-of-the-circumstances probable cause analysis required by Green.The Supreme Court of Tennessee held that the best practice is for trial courts to conduct an on-the-record colloquy to determine whether a certified question is dispositive. The Court further held that if an appellate court finds a certified question is not dispositive, it must vacate the conviction and remand so the defendant may withdraw the conditional plea. In this case, the Supreme Court determined the certified question was dispositive in light of Green and reversed the dismissal by the Court of Criminal Appeals, remanding for consideration of the merits. View "State of Tennessee v. Bishop" on Justia Law

A pregnant patient was admitted to a medical center, where she suffered an anaphylactic reaction to medication administered for a streptococcus infection. Her treating physician and hospital staff provided various treatments but did not administer epinephrine, a standard treatment for anaphylaxis. The patient’s child was born with severe brain injuries, which the plaintiff alleged were caused by the anaphylactic episode and the defendants’ failure to use epinephrine. The plaintiff sued the physician and medical entities for healthcare liability, contending that the physician’s decision not to use epinephrine fell below the standard of care and that the hospital staff was negligent in monitoring.After an initial trial ended in a defense verdict but was set aside due to evidentiary errors, a second jury trial again resulted in a verdict for the defendants. Following the second trial, it was discovered that a juror had, during deliberations, conducted personal research by reading an EpiPen warning label at home and shared its contents with the other jurors. The plaintiff moved for a new trial, arguing this extraneous information affected the verdict. The Circuit Court for Knox County denied the motion, ruling the plaintiff had not proven by clear and convincing evidence that the jury was influenced by the information.On appeal, the Tennessee Court of Appeals reversed, holding the trial court had applied the wrong legal standard and that prejudice should be presumed when jurors are exposed to extraneous, material information. The defendants then sought review.The Supreme Court of Tennessee held that, in civil cases involving the constitutional right to a jury trial, courts must use a burden-shifting framework: the party challenging a verdict must first prove by a preponderance of the evidence that the jury was exposed to material extraneous information, which triggers a rebuttable presumption of prejudice. The party defending the verdict must then show there is no reasonable possibility the information altered the verdict. The Court vacated the decision of the Court of Appeals and remanded for the trial court to apply this framework. View "Collier ex rel. Chayce C. v. Roussis" on Justia Law

After a motor vehicle accident in Knoxville, Tennessee, a child sustained serious injuries while riding in a booster seat secured with a seatbelt extender. The seatbelt extender, manufactured by Ford Motor Company, was purchased and installed by the child’s father to address difficulties buckling the booster seat in their Nissan Juke. Both the booster seat and the seatbelt extender were not inherently defective for their intended purposes, but the plaintiff alleged that using the two products together created a dangerous condition. The plaintiff filed a product liability action under the Tennessee Products Liability Act, asserting that Ford failed to adequately warn against the risks of using its seatbelt extender in combination with a booster seat.The Circuit Court for Knox County initially granted summary judgment to Dorel Juvenile Group, the booster seat manufacturer, but denied Ford’s motion for summary judgment, finding Ford to be a manufacturer or seller under the Act. After a mistrial in the plaintiff’s claim against Ford, the trial court allowed an interlocutory appeal to address whether the Tennessee Supreme Court’s prior decision in Coffman v. Armstrong International, Inc. required dismissal of the failure-to-warn claims. The Court of Appeals reversed the trial court, holding that Coffman barred the plaintiff’s claims as a matter of law.The Supreme Court of Tennessee reviewed the certified question and clarified that Coffman, which involved post-sale integration of inherently dangerous asbestos-containing materials into a sound product, does not require dismissal as a matter of law of failure-to-warn claims when two independently sound products are used together and create a dangerous condition. The Court reversed the judgment of the Court of Appeals and remanded the case to the trial court for further proceedings, holding that Coffman does not foreclose the plaintiff’s failure-to-warn claims under these circumstances. View "Woodruff v. Ford Motor Co." on Justia Law

A serious automobile accident in Knoxville, Tennessee resulted in the death of Benjamin Woodruff and severe injuries to his six-year-old son, Ethan. At the time of the crash, Ethan was in a high-backed booster seat manufactured by Dorel Juvenile Group and was restrained using a seatbelt extender made by Ford Motor Company, which had been purchased separately to address difficulties in buckling the booster seat in the family’s Nissan Juke. The booster seat’s manual referenced the possible use of a seatbelt extender, while the vehicle’s manual warned against using extenders to install child restraints. After the accident, Sarah Woodruff filed a product liability lawsuit under the Tennessee Products Liability Act, alleging that both Dorel and Ford failed to adequately warn of the dangers of using a seatbelt extender with the booster seat.The Circuit Court for Knox County initially granted summary judgment to Dorel, finding it had no duty to warn about another manufacturer’s product, but denied summary judgment to Ford. After an intervening decision by the Tennessee Supreme Court in Coffman v. Armstrong International, Inc., the trial court vacated its grant of summary judgment to Dorel, then later reinstated it after further motions. The Court of Appeals affirmed the grant of summary judgment for Dorel, holding that Coffman barred the plaintiff’s failure-to-warn claim as a matter of law since Dorel’s product was only allegedly dangerous when used with another manufacturer’s product.The Supreme Court of Tennessee reviewed the case and clarified that its prior holding in Coffman does not mandate dismissal as a matter of law of the plaintiff’s failure-to-warn claim against Dorel. The Court explained that Coffman was limited to situations involving the integration of inherently dangerous components into another product post-sale, and does not foreclose failure-to-warn claims where two sound products together create a risk. The Supreme Court of Tennessee reversed the Court of Appeals and remanded for further proceedings. View "Woodruff ex rel. Woodruff v. Ford Motor Co." on Justia Law

A seventeen-year-old defendant was implicated in the fatal shootings of two individuals at an apartment complex in Milan, Tennessee. Law enforcement identified the defendant and a co-defendant as suspects based on anonymous tips and information from onlookers. The defendant was interrogated at the police station without the presence of his mother, despite her being at the station and his repeated requests for her. Over the course of nearly seven hours, he ultimately confessed to participating in the shootings after being told, among other things, that he could face the death penalty and subjected to other coercive tactics. No weapons were recovered, but ballistics indicated two firearms were used. Cell phone records and eyewitness testimony linked the defendant to the scene.The Gibson County Juvenile Court held a transfer hearing and, after considering statutory factors and the evidence presented, found probable cause and transferred the defendant to Circuit Court to be tried as an adult. The court suppressed the defendant’s confession for purposes of the transfer decision. Subsequently, the Circuit Court denied a motion to suppress the confession, finding it voluntary and admissible. At trial, the defendant was convicted by a jury of two counts of second-degree murder. The Tennessee Court of Criminal Appeals affirmed, holding that the transfer was appropriate and the confession voluntary.The Supreme Court of Tennessee reviewed the case. It held that the juvenile court properly transferred the defendant after finding probable cause and satisfying all statutory requirements. The Supreme Court further held that the defendant validly waived his Fifth Amendment right to remain silent. However, the court found that the confession was involuntary, having been obtained through coercion in violation of the Due Process Clause. As a result, the Supreme Court vacated the convictions and remanded the case for further proceedings, excluding the coerced confession from any retrial. View "State v. Adkisson" on Justia Law