Justia Tennessee Supreme Court Opinion Summaries

After injuring another student, a public high school student was cited for an infraction of the student conduct rule proscribing reckless endangerment. The principal's decision to suspend the student for ten days was upheld by a hearing board and the director of schools. Thereafter, the student and his family sought judicial review of the disciplinary decision. The trial court concluded (1) the school officials had violated the student's procedural due process rights because one official had performed both prosecutorial and decision-making functions and because this official was biased against the student; and (2) the evidence did not support the conclusion that the student's conduct amounted to reckless endangerment. Accordingly, the court directed the school system to expunge the student's record and awarded the student and his family attorneys' fees and costs. The court of appeals reversed. The Supreme Court affirmed, holding (1) the student received the required due process protections before he was suspended; (2) the hearing process after the student was suspended as applied did not render the proceedings fundamentally unfair; and (3) the court of appeals did not err by overturning the trial court's conclusion that the school officials acted arbitrarily and illegally.View "Heyne v. Metro. Nashville Bd. of Pub. Educ." on Justia Law

When the nursing staff at the assisted living facility where Mable Farrar lived did not give Farrar an over-the-counter medicine for constipation as often as her doctor had prescribed, Farrar became constipated. Thereafter, Farrar's doctor notified the staff at the facility to give Farrar three to four enemas each day. A facility nurse gave Farrar only two enemas in three days. Farrar subsequently died of a perforated colon. Farrar's daughters filed a wrongful death action against the nurse who gave the enemas, the director of nursing at the facility, the owner of the facility, and the facility's management company. The jury found the management company fifty percent at fault based on its failure to provide sufficient personnel at the facility. The court of appeals reversed the jury verdict against the management company, finding that there was no material evidence that staffing deficiencies proximately caused Farrar's death. The Supreme Court reversed the court of appeals and reinstated the jury verdict, holding that material evidence supported the jury's finding that the management company's conduct was a substantial factor in causing Farrar's death. Remanded for review of the award of punitive damages. View "Wilson v. Americare Sys., Inc." on Justia Law

Employer, a temporary staffing agency, assigned Employee to work temporarily at a manufacturing facility. Employee suffered a work-related injury during the assignment and reported the injury to Employer. At approximately the same time, the manufacturing facility ended Employee's assignment. Employer subsequently terminated Employee's employment and did not return Employee to work. The trial court awarded Employee workers' compensation benefits but capped the award at one and one-half times the medical impairment rating. The special workers' compensation appeals panel vacated the trial court's judgment and remanded for a determination of whether Employee had a meaningful return to work. The Supreme Court vacated the judgments of the lower courts, holding that because Employer neither returned Employee to work after his injury, nor offered him an opportunity to work, nor terminated his employment for misconduct, Employee's benefits award was governed by the statute authorizing benefits up to six times the medical impairment rating rather than the statute capping benefits at one and one-half times the medical impairment rating. Remanded. View "Britt v. Dyer's Employment Agency, Inc." on Justia Law

Employee was injured while in the course of scope of his employment through the actions of a third-party tortfeasor (Tortfeasor). Employee filed a claim for workers' compensation benefits and a lawsuit against Tortfeasor. Employer intervened in the lawsuit to protect its subrogation lien against any recovery from Tortfeasor. Employee settled the lawsuit with Tortfeasor and dismissed the case. Employer filed a motion to set the case for trial, asserting that it was entitled to a lien against the settlement proceeds for the cost of future medical benefits that may be paid on behalf of Employee. After initially setting the case for trial, the trial court dismissed for failure to state a claim. The court of appeals reversed and remanded, concluding that future medical expenses are not too speculative as a matter of law to be included in an employer's lien against the proceeds of a suit against a third-party tortfeasor. The Supreme Court reversed, holding that Employer failed to state a claim for which relief can be granted, as Employer's subrogation lien against the proceeds of the settlement did not extend to the cost of future medical benefits to which Employee may be entitled. View "Cooper v. Logistics Insight Corp." on Justia Law

Defendant, a crematory operator, hid hundreds of uncremated bodies on his property rather than perform cremations he was paid to do. When Plaintiffs, who had received what they thought to be their deceased son's cremains from Defendant's crematory, learned about the problems at the crematory, they discovered the body of their son was mishandled and not properly cremated. Plaintiffs sued Defendant for the alleged mishandling of their deceased son's body. Following a jury verdict for Plaintiffs, the trial court entered judgment against Defendant based on the intentional infliction of emotional distress claim but granted his motion for a judgment notwithstanding the verdict on Plaintiffs' Tennessee Consumer Protection Act (TCPA) and bailment claims. The court of appeals affirmed. The Supreme Court affirmed, holding that the trial court did not err in (1) holding Defendant liable for intentional infliction of emotional distress in the amount of the jury verdict; (2) instructing the jury that they were permitted to draw a negative inference resulting from Defendant's invocation of his Fifth Amendment privilege during questioning; and (3) dismissing the TCPA and bailment claims. View "Akers v. Prime Succession of Tenn., Inc." on Justia Law

A patient discovered that a guide wire had been left in her vein during a prior medical procedure. She filed a medical malpractice action against the doctors who performed the procedure and the hospital where the procedure was performed. The patient voluntarily dismissed the medical malpractice suit pursuant to Tenn. R. Civ. P. 41 when she was informed that another party was responsible for the presence of the guide wire. The doctors named in the original suit filed a malicious prosecution action against the patient. The patient filed a motion for summary judgment alleging that the doctors could not prove that the prior suit had been terminated in their favor. The trial court denied the motion for summary judgment, and the court of appeals affirmed. The Supreme Court reversed, held that a voluntary nonsuit taken pursuant to Rule 41 is not a favorable termination on the merits for purposes of a malicious prosecution claim. Remanded for entry of summary judgment in favor of the patient. View "Himmelfarb v. Allain" on Justia Law

Jerry and Martha Garrison witnessed their son's injuries after he was struck by a car. The son died afterwards. The Garrisons filed a claim for negligent infliction of emotional distress against the owner and driver of the car. The Garrisons also served a copy of the complaint upon their insurance company, State Farm, pursuant to the uninsured motorist provisions of their policy. The policy covered damages for "bodily injury," and "bodily injury" was defined in the policy as "bodily injury to a person and sickness, disease, or death that results from it." The trial court determined that the "bodily injury" provision of the uninsured motorist statute covered mental injuries, and therefore, the policy provided, by operation of law, coverage for the Garrisons' emotional distress claim. The court of appeals reversed. The Supreme Court affirmed, holding (1) as applied to this case, "bodily injury" did not include damages for emotional harm alone; and (2) the definition of "bodily injury" in the policy did not conflict with the uninsured motorist statute. View "Garrison v. Bickford " on Justia Law

In the workers' compensation case underlying this interlocutory appeal, Employee and Employer were unable to reach a resolution. A benefit review report submitted at 10:25 a.m. on October 20, 2011 memorialized the impasse. On the same day, Employee filed a complaint seeking workers' compensation benefits in the chancery court. The time stamp affixed by the court clerk indicated the complaint was filed at 10:22 a.m. In response to Employee's complaint, Employer filed a motion to dismiss for lack of jurisdiction, arguing that Employee's complaint had been filed prematurely. After Employee filed affidavits averring he did not file the complaint until after he received the benefit review repor, the chancery court determined it had subject matter jurisdiction and denied the motion to dismiss. The Supreme Court reversed, holding (1) a complaint may not be filed until the time noted on the benefit review report; and (2) when a complaint bears an unambiguous time stamp, it shall be deemed filed t the time indicated, and the time stamp may not be impeached by extrinsic evidence. View "Word v. Metro Air Servs., Inc." on Justia Law

This personal injury suit arose from an automobile accident involving Jeffrey Callicutt and the Manns. The Manns sued Jeffrey's parents (the Callicutts) within the one-year statute of limitations. The Manns amended their complaint to name, as additional defendants, Appellees. Thereafter, Appellees filed dispositive motions in which they contended that the one-year statute of limitations had expired before they were named as parties. The trial court granted Appellees' dispositive motions in a non-final order. Less than one week later, the Callicutts named Appellees as comparative tortfeasors in their amended answer. The Manns named Appellees as additional tortfeasors within ninety days of the Callicutts' amended answer. The Manns subsequently filed a second amended complaint, alleging the same claims against the same defendants. The trial court granted Appellees' dispositive motions attacking the second amended complaint as barred by the one-year statute of limitations. The court of appeals affirmed. The Supreme Court reversed, holding (1) the dismissal of a defendant pursuant to a written order not made final renders that defendant "not a party to the suit" for purposes of Tenn. Code Ann. 20-1-119; and (2) thus, the court of appeals erred in upholding the trial court's dismissal of Appellees from the suit. View "Mann v. Alpha Tau Omega Fraternity" on Justia Law

Employee viewed the bodies of co-workers who had died as a result of work accidents on two separate occasions in February and April 2008. On June 23, 2008, Employee was diagnosed with post-traumatic stress disorder (PTSD) caused by the two incidents. On June 23, 2009, the employee requested a benefit review conference. Employer filed a complaint to determine the amount of workers' compensation benefits due. Employer subsequently filed a motion for summary judgment contending that the statute of limitations commenced on the date of the second accident and that the claim was therefore barred. Employee contended that the statute did not begin to run until the date of his diagnosis and that his claim was timely. The trial court granted Employer's motion. The Supreme Court reversed, holding (1) the limitations period did not commence until Employee was diagnosed as having PTSD on June 23, 2008; and (2) the statute of limitations therefore did not bar Employee's claim. View "Gerdau Ameristeel, Inc. v. Ratliff" on Justia Law