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

An elderly woman with severely impaired cognitive functioning was a resident at a skilled nursing facility. While an employee was helping her shower, the employee took a personal video call and propped her phone in a way that displayed the resident’s nude body to the caller. The resident’s conservator sued the facility for invasion of privacy. The trial court granted summary judgment in favor of the facility, and the plaintiff appealed. During the appeal, the resident died, and her estate was substituted as the plaintiff.The Court of Appeals reversed the trial court’s decision, holding that the complaint stated a valid claim for invasion of privacy based on intrusion upon seclusion and that the claim did not abate upon the resident’s death. The defendant facility was granted permission to appeal on the issue of abatement.The Supreme Court of Tennessee reviewed the case and held that under Tennessee Code Annotated section 20-5-102, a cause of action for invasion of privacy based on intrusion upon seclusion does not abate upon the death of the person whose privacy was invaded. The court determined that the statutory exception for “wrongs affecting the character of the plaintiff” did not apply to this case. Therefore, the court affirmed the Court of Appeals' decision that the claim for intrusion upon seclusion did not abate upon the resident’s death and remanded the case to the trial court for further proceedings. View "Jones v. Life Care Centers of America" on Justia Law

Clayton D. Richards underwent a medical procedure at Vanderbilt University Medical Center (VUMC) in August 2013, resulting in bilateral lower extremity paralysis. He initially filed a negligence lawsuit against VUMC in December 2014, which he later voluntarily dismissed. Richards refiled his complaint in January 2021, relying on Tennessee's saving statute, Tennessee Code Annotated section 28-1-105, which allows a plaintiff to refile a lawsuit within one year of a voluntary nonsuit. However, the trial court dismissed his complaint, ruling that Richards did not comply with the saving statute's terms.The Circuit Court for Davidson County dismissed Richards' refiled complaint, holding that it was not filed within the one-year period required by the saving statute. Richards argued that Tennessee Code Annotated section 29-26-121(c) provided him with a 120-day extension to the one-year saving statute, making his lawsuit timely. The Court of Appeals affirmed the trial court's dismissal, agreeing that the 120-day extension did not apply to the saving statute.The Supreme Court of Tennessee reviewed the case and affirmed the lower courts' decisions. The court held that Tennessee Code Annotated section 29-26-121(c) does not extend the one-year refiling period provided by the saving statute. The court emphasized that the 120-day extension applies only to statutes of limitations and repose, not to the saving statute. Consequently, Richards' refiled complaint was untimely, and the trial court's dismissal of the case was upheld. View "Richards v. Vanderbilt University Medical Center" on Justia Law

Pharma Conference Education, Inc. entered into an agreement with the University of Tennessee Health Science Center to produce pharmaceutical continuing education programs "as is feasible." The Health Science Center terminated the agreement before any programs were held. Pharma sued to enforce the agreement, but the State argued that the agreement lacked consideration and was not a valid contract. The key issue was whether the promise to produce programs "as is feasible" constituted consideration or was an illusory promise.The Tennessee Claims Commission granted summary judgment in favor of the State, concluding that the agreement lacked consideration because Pharma's promise was illusory. The Court of Appeals affirmed, agreeing that Pharma's promise gave it complete discretion and was therefore illusory. Both courts relied on the deposition testimony of Pharma's president, John W. Smith, to support their conclusions.The Supreme Court of Tennessee reviewed the case and held that Pharma's promise to produce as many programs "as is feasible" constitutes adequate consideration. The Court explained that the term "feasible" has an objective meaning and does not give Pharma unfettered discretion. The Court also noted that the statutory presumption of consideration under Tennessee Code Annotated section 47-50-103 applies, and the State failed to rebut this presumption. The Court reversed the Court of Appeals' decision and remanded the case to the Claims Commission for further proceedings, including consideration of the State's argument regarding mutual assent. View "Pharma Conference Education, Inc. v. State" on Justia Law

Robert E. Lee Flade filed a lawsuit against several defendants, including Stephanie Isaacs and the Bedford County Listening Project (BCLP), over disparaging remarks made on social media. Isaacs and the BCLP filed motions to dismiss under Rule 12.02(6) of the Tennessee Rules of Civil Procedure and petitions to dismiss under the Tennessee Public Participation Act (TPPA), seeking dismissal with prejudice, attorney’s fees, and sanctions. Before the trial court could hear these motions, Flade voluntarily dismissed his complaint without prejudice. Isaacs and the BCLP requested the court to adjudicate their TPPA petitions despite the dismissal, but the trial court declined, stating the nonsuit concluded the matter.The Court of Appeals affirmed the trial court’s decision, holding that the TPPA petitions did not limit Flade’s right to a voluntary nonsuit under Rule 41.01(1). The court reasoned that the TPPA did not specifically limit the right to a nonsuit and that the mere filing of a TPPA petition did not create a vested right that would prevent a voluntary dismissal.The Supreme Court of Tennessee reviewed the case and affirmed the Court of Appeals' judgment. The court held that the right to take a voluntary nonsuit is not subject to the provisions of the TPPA under Rule 41.01(1). It also concluded that there is no vested right to adjudication of a TPPA petition pending at the time of a voluntary nonsuit and that a TPPA petition does not constitute a counterclaim for purposes of Rule 41.01(1). Therefore, the trial court correctly declined to adjudicate the TPPA petitions after Flade voluntarily dismissed his complaint. View "Flade v. City of Shelbyville, Tennessee" on Justia Law

The plaintiffs alleged that the defendants committed fraud related to property rights. The defendants, through their business, REO Holdings, LLC, bought properties at tax sales and used redemption rights to obtain titles, some of which were later found to be fraudulent. The case involved four specific properties where the defendants allegedly used misrepresentation and forged documents to redeem and sell the properties at a profit.The Chancery Court for Davidson County initially dismissed the plaintiffs' claims for unjust enrichment and misappropriation of redemption rights, finding that unjust enrichment required a voluntary conferral of a benefit and that Tennessee law did not recognize conversion of intangible property rights. The court also denied class certification. After a jury trial, the plaintiffs moved for a new trial, arguing that the evidence preponderated against the jury’s verdict. The trial court denied the motion, and the Court of Appeals reversed, finding that the trial court misconceived its role as thirteenth juror.The Supreme Court of Tennessee reviewed the case and held that remand for the trial court to fulfill its role as thirteenth juror is an appropriate remedy when a civil trial court misconceives that role or applies an incorrect standard. The court also held that a claim for unjust enrichment does not require a voluntary conferral of a benefit, overruling previous case law to the extent it held otherwise. Finally, the court affirmed that Tennessee law does not recognize a claim for misappropriation or conversion of a right of redemption. The decision of the Court of Appeals was affirmed in part and reversed in part, and the case was remanded for further proceedings consistent with the opinion. View "Family Trust Services LLC v. Green Wise Homes LLC" on Justia Law

The case involves a defamation claim brought by Bill Charles, a real estate professional and president of the homeowners' association of the Durham Farms community in Hendersonville, Tennessee, against Donna McQueen, a resident of the same community. McQueen had posted a critical review of Charles on Google, accusing him of using misleading tactics to deceive home buyers. Charles filed a defamation and false light claim against McQueen, who sought dismissal of the claims under the Tennessee Public Participation Act, arguing that Charles could not establish a prima facie case for his claims because he could not prove actual malice.The trial court agreed with McQueen and dismissed the claims. The Court of Appeals reversed in part, agreeing that Charles had to prove actual malice for his false light claim but holding that Charles was not a public figure and therefore did not need to prove actual malice for his defamation claim.The Supreme Court of Tennessee disagreed with the Court of Appeals, holding that Charles is a limited-purpose public figure given his voluntary and prominent role in a controversy concerning changes to the Durham Farms development plan. The court further held that Charles failed to establish a prima facie case of actual malice. The court also rejected Charles’s argument that McQueen waived her request for appellate attorney’s fees by failing to list it as an issue in her Court of Appeals brief. The court reversed the Court of Appeals in part and affirmed in part, remanding the case for further proceedings. View "Charles v. McQueen" on Justia Law

This case involves a conservatorship dispute over Susan Davis Malone. Two attorneys involved in the case filed two motions requesting the trial judge to recuse himself. The first recusal motion was denied and affirmed on appeal. The second recusal motion was also denied. The attorneys then filed a second petition for recusal appeal, arguing that trial court orders entered after the Court of Appeals issued its opinion in the first recusal appeal, but before the mandate issued, are void for lack of subject matter jurisdiction.The Court of Appeals agreed with the attorneys and held that the orders were void. The counterpetitioners and co-conservators then filed an accelerated application for permission to appeal in the Supreme Court of Tennessee.The Supreme Court of Tennessee granted the application and reversed the judgment of the Court of Appeals. The court held that the stay imposed by the Court of Appeals in the first recusal appeal did not divest the trial court of subject matter jurisdiction over the case. The court also held that the attorneys waived any other argument that orders entered by the trial court should be vacated because they were entered prior to issuance of the mandate. The case was remanded for further proceedings consistent with this decision. View "In Re Conservatorship of Malone" on Justia Law

The case involves a slip and fall incident at a Trader Joe's grocery store in Nashville, Tennessee. The plaintiff, Melissa Binns, alleged that she slipped and fell due to the negligence of an employee who was stocking shelves in a disorganized manner, causing a package of tofu to fall and spill liquid on the floor. Binns filed a complaint against Trader Joe's East, Inc., alleging premises liability, negligent training, and negligent supervision. Trader Joe's sought to dismiss the negligent training and supervision claims, arguing that these claims should be dismissed when asserted concurrently with a premises liability claim and that the plaintiff's direct negligence claims were no longer viable due to the defendant admitting it was vicariously liable for the conduct of its employee.The trial court rejected both of Trader Joe's arguments and denied its motion for partial judgment on the pleadings. The court granted permission for an interlocutory appeal, which was denied by the Court of Appeals. Trader Joe's then appealed to the Supreme Court of Tennessee, which granted review.The Supreme Court of Tennessee held that the preemption rule, which would dismiss direct negligence claims when a defendant admits vicarious liability, is incompatible with Tennessee's system of comparative fault and declined to adopt it. The court also declined to adopt the rule proposed by Trader Joe's that "negligent activity" claims cannot be asserted alongside premises liability claims. As a result, the court affirmed the trial court's order denying Trader Joe's motion for partial judgment on the pleadings and remanded the case back to the trial court for further proceedings. View "Binns v. Trader Joe's East, Inc." on Justia Law