Justia Tennessee Supreme Court Opinion Summaries

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The Supreme Court reversed the decision of the court of appeals upholding that trial court's determination that the plaintiff homeowner's award of attorneys fees and costs under Tenn. Code Ann. 20-12-119(c) was limited to those incurred after the date the defendant contractor filed an amended countercomplaint, holding that the lower courts erred.Plaintiff and Defendant entered into a contract for the renovation of a residence. Plaintiff later filed a complaint alleging breach of contract and violation of the Tennessee Consumer Protection Act. Defendant filed an amended countercomplaint asserting breach of contract. The trial court dismissed all of Plaintiff's claims and then dismissed the countercomplaint. On appeal, Plaintiff challenged the attorney fee and costs award granted by the trial court. The court of appeals affirmed. The Supreme Court vacated the trial court's award of attorney fees and costs, holding that the fees and costs recoverable by Plaintiff in connection with the dismissal of Defendant’s breach of contract claim are not limited to those incurred after the amended countercomplaint was actually filed. View "Donovan v. Hastings" on Justia Law

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Phillips was convicted of offenses, including felony murder, attempted first-degree murder, aggravated rape, especially aggravated kidnapping, and especially aggravated burglary. The Court of Criminal Appeals modified the especially aggravated burglary conviction to aggravated burglary. Phillips sought post-conviction relief, asserting that his trial counsel was constitutionally ineffective by failing to seek suppression of various statements he made to police. The Court of Criminal Appeals affirmed the denial of relief.The Tennessee Supreme Court affirmed, clarifying the petitioner’s burden to establish prejudice when he alleges counsel was constitutionally ineffective for failing to file a motion to suppress on Fourth Amendment grounds: The petitioner must prove that his Fourth Amendment claim is meritorious and that there is a reasonable probability that the verdict would have been different absent the excludable evidence. Despite the Fourth Amendment concerns brought about by the Memphis Police Department’s use of a 48-hour hold policy, there is no proof that the probable cause determination was unreasonably delayed and Phillips’s arrest was supported by probable cause. Given the proof of his guilt, Phillips has not established a reasonable probability that his verdict would have been different had his statements to the police been suppressed. View "Phillips v. State of Tennessee" on Justia Law

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Starbuck filed a nominating petition seeking to be placed on the ballot for the Republican primary for Tennessee’s 5th Congressional District for the U.S. House of Representatives. The Tennessee Republican Party, through the Tennessee Republican Party State Executive Committee (TRP SEC), determined that Starbuck was not a bona fide Republican, and would not appear on the ballot. Starbuck sought declaratory and injunctive relief, alleging that the defendants violated the Tennesse Open Meetings Act (TOMA), Tenn. Code 8-44-101-111, by determining in a non-public meeting that he is not a bona fide Republican.The trial court concluded that the defendants violated TOMA and ordered that Starbuck be restored to the ballot. The Tennessee Supreme Court assumed jurisdiction and vacated. Only the state primary boards, not the state executive committees, are required to comply with TOMA (Tenn. Code 2-13-108(a)(2)). Section 2-13-104 provides that “a party may require by rule that candidates for its nominations be bona fide members of the party.” Under section 2-5-204(b)(2), a party’s state executive committee makes the determination of whether a candidate is a bona fide member of the party. TRP SEC, by statute, was acting as a state executive committee, and not a state primary board, when it determined that Starbuck was not a bona fide Republican and was not required to comply with TOMA. View "Newsom v. Tennessee Republican Party" on Justia Law

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The Supreme Court affirmed the judgments of the trial court convicting and sentencing Defendant for multiple drug offenses that occurred in a drug-free zone within 1,000 feet of a city park, holding that the offenses were subject to the requirement to serve in full at least the minimum sentence for the appropriate range prior to release.Because Defendant's offenses occurred in a drug-free zone, the trial court imposed sentences that required full service of at least the minimum term within the appropriate sentencing range prior to release. The court of criminal appeals concluded sua sponte that the felony class reflected on the judgment for one conviction was incorrect. The Supreme Court reversed in part and affirmed the judgments of the trial court, holding (1) because the drug-free zone related to a public park, the offenses were not subject to a one-class enhancement; but (2) the offenses were subject to the requirement to serve in full at least the minimum sentence for the appropriate range prior to release. View "State v. Linville" on Justia Law

Posted in: Criminal Law
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In this interlocutory appeal, the Supreme Court held that the Tennessee Bureau of Investigation (TBI) lacked the authority to refuse to comply with a final expungement order issued by the trial court.After Plaintiff had successfully completed probation he petitioned for expungement of his records and paid the expungement fee. The trial judge entered an expunction order. After the order became final, Plaintiff learned that the TBI had continued to report the existence of one of the expunged charged offenses. Plaintiff sued the TBI seeking declaratory and injunctive relief. The trial court declined to grant either party's motion for partial judgment on the pleadings. The Supreme Court reversed and granted Plaintiff's motion for partial judgment on the pleadings, holding that Plaintiff's expunction order was res judicata and binding on the TBI. View "Recipient of Final Expunction Order v. Rausch" on Justia Law

Posted in: Criminal Law
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In this case concerning a constitutional challenge to the Tennessee Education Savings Account Pilot Program (the ESA Act), Tenn. Code Ann. 49-6-2601, the Supreme Court held that the ESA Act does not implicate the Home Rule Amendment, Tenn. Const. Art. XI, 9, such that the Act is not rendered unconstitutional by the Amendment.The trial court granted summary judgment in favor of Plaintiffs, holding (1) Plaintiffs had standing to pursue this claim, and (2) the ESA Act is unconstitutional under the Home Rule Amendment. The court of appeals affirmed. The Supreme Court reversed in part, holding Plaintiffs had standing to bring their Home Rule Amendment claim; but (2) the ESA Act does not implicate the Home Rule Amendment such that the Act is not rendered unconstitutional pursuant to that Amendment. View "Metropolitan Government of Nashville & Davidson County v. Tennessee Department of Education" on Justia Law

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The Supreme Court vacated Defendant's convictions, holding that the trial court committed reversible error by allowing impeachment evidence of a material defense witness without sufficient evidence, and the error was not harmless.After a jury trial, Defendant was convicted of attempted second-degree murder and unlawful employment of a firearm. The court of criminal appeals affirmed, holding, as relevant to this appeal, that Defendant's right to a speedy trial had not been violated and that the trial court did not commit reversible error in allowing improper impeachment of a defense witness. The Supreme Court reversed, holding (1) Defendant was not denied a speedy trial; but (2) the trial court's error in allowing improper impeachment evidence was reversible error. View "State v. Moon" on Justia Law

Posted in: Criminal Law
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In this appeal concerning the revocation of Defendant's probation the Supreme Court affirmed the court of criminal appeals' decision affirming the judgment of the trial court revoking Defendant's probation and ordering him to serve the balance of his sentence, holding that a probation revocation proceeding ultimately involves a two-step inquiry.At issue was whether revocation proceedings are a one-step or two-step process and the appropriate appellate standard of review to be used in reviewing such determinations. The Supreme Court held (1) a probation revocation proceeding involves a two-step process; and (2) if the trial court has properly placed its findings on the record, the standard of review for probation revocations is abuse of discretion with a presumption of reasonableness. View "State v. Dagnan" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the judgments of the court of appeals and the trial court concluding that the Health Care Liability Act, Tenn. Code Ann. 29-26-101 to -122, did not apply to Plaintiffs' medical battery and intentional misrepresentation claims, holding that Plaintiffs' claims fell within the definition of a "healthcare liability action" under the Act.Plaintiffs sued a doctor and his medical practice alleging medical battery and intentional misrepresentation. Defendants filed a motion to dismiss on the grounds that Plaintiffs did not comply with the Act's pre-suit notice and filing requirements. The trial court agreed, ruling that Defendants' misrepresentations were made before they rendered any health care services and therefore did not relate to the provision of health care services. The court of appeals affirmed. The Supreme Court reversed, holding that the Act applied to Plaintiffs' claims. View "Cooper v. Mandy" on Justia Law

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The Supreme Court affirmed the dismissal of Melissa Kampmeyer's loss of consortium claim brought after her husband, Steven Kampmeyer, was injured in an accident, holding that Tenn. Code Ann. 9-8-402(a)(1) requires claimants to give written notice of their claim to the Division of Claims and Risk Management as a condition precedent to recovery.Steven was injured when his car collided with a Tennessee state vehicle parked in the roadway. Steven gave written notice of his claim to the Tennessee Division of Claims and Risk Management, which transferred the claim to the Tennessee Claims Commission. Steven and Melissa then filed a complaint with the Claims Commission. The complaint contained Melissa's loss of consortium claim, which was not in the written notice Steven gave to the Division of Claims and Risk Management. The Claims Commission dismissed Melissa's loss of consortium claim as time-barred. The Supreme Court affirmed, holding that because Melissa did not give written notice of her claim to the Division of Claims and Risk Management within the one-year statute of limitations, her loss of consortium claim was time-barred. View "Kampmeyer v. State" on Justia Law