Justia Tennessee Supreme Court Opinion Summaries

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

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