Justia Tennessee Supreme Court Opinion Summaries

In 2014, Emergency Medical Care Facilities, P.C. (EMCF) filed a putative class action against BlueCross BlueShield of Tennessee, Inc. (BCBST), alleging breach of contract due to a cap on certain payments for medical services. The trial court denied class certification, and the Court of Appeals affirmed. EMCF then voluntarily nonsuited its claims. After a favorable ruling in a separate lawsuit against TennCare, EMCF refiled its case against BCBST, again seeking class certification.The trial court held that collateral estoppel precluded relitigation of class certification, but the Court of Appeals reversed, stating that the prior class certification denial was not final for collateral estoppel purposes because the case had been voluntarily nonsuited.The Supreme Court of Tennessee reviewed the case to determine whether the prior denial of class certification, affirmed on appeal, was entitled to preclusive effect. The Court held that the trial court's and appellate court's decisions denying class certification in the earlier case were final and binding for purposes of collateral estoppel. The Court reasoned that the class certification issue had been fully litigated and decided, and the decision was subject to appeal, which EMCF did not pursue further. Therefore, EMCF was precluded from relitigating the class certification issue in the refiled case.The Supreme Court of Tennessee reversed the Court of Appeals' decision and remanded the case to the trial court, reinstating the order striking the class action allegations against BCBST and VSHP. The Court emphasized that the denial of class certification, affirmed on appeal, was sufficiently final to warrant preclusive effect, preventing EMCF from seeking a do-over on class certification. View "Emergency Medical Care Facilities, P.C. v. BlueCross BlueShield of Tennessee, Inc." on Justia Law

American Heritage Apartments, Inc., a customer of the Hamilton County Water and Wastewater Treatment Authority (County Authority), filed suit both individually and as a class representative asserting that the County Authority exceeded its statutory authority by imposing a monthly charge on its customers. The County Authority sought dismissal of the lawsuit for failure to exhaust administrative remedies, arguing that a customer who seeks to dispute the rates charged must first follow the administrative procedures provided in the Utility District Law of 1937 (UDL). The trial court agreed and dismissed the lawsuit. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) the administrative procedures in Part 4 of the UDL do not apply to a rate challenge filed by an individual customer against a water and wastewater treatment authority, and therefore, the trial court erred in dismissing the lawsuit for failure to exhaust administrative remedies; and (2) the trial court’s alternative ruling on class certification is vacated, and that issue is remanded to the trial court for reconsideration. View "Am. Heritage Apartments, Inc. v. Hamilton County Water & Wastewater Treatment Auth." on Justia Law

American Heritage Apartments, Inc., a customer of the Hamilton County Water and Wastewater Treatment Authority (County Authority), filed suit both individually and as a class representative asserting that the County Authority exceeded its statutory authority by imposing a monthly charge on its customers. The County Authority sought dismissal of the lawsuit for failure to exhaust administrative remedies, arguing that a customer who seeks to dispute the rates charged must first follow the administrative procedures provided in the Utility District Law of 1937 (UDL). The trial court agreed and dismissed the lawsuit. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) the administrative procedures in Part 4 of the UDL do not apply to a rate challenge filed by an individual customer against a water and wastewater treatment authority, and therefore, the trial court erred in dismissing the lawsuit for failure to exhaust administrative remedies; and (2) the trial court’s alternative ruling on class certification is vacated, and that issue is remanded to the trial court for reconsideration. View "Am. Heritage Apartments, Inc. v. Hamilton County Water & Wastewater Treatment Auth." on Justia Law