Justia Tennessee Supreme Court Opinion Summaries

While on duty, Dennis Harris, a patrolman with the Anderson County Sheriff’s Department, was struck by a pickup truck driven by Mickey Haynes. Harris received workers’ compensation benefits for his injuries. Harris and his wife (together, Plaintiffs) sued Haynes and Richard Furrow, neither of whom were insured. Plaintiffs also made a claim against Tennessee Risk Management Trust (TRMT), Anderson County’s motor vehicle liability coverage provider, for uninsured motorist coverage. The trial court granted summary judgment for TRMT. The Court of Appeals affirmed, concluding (1) TRMT was a “risk pool” and not an insurance policy, and therefore, the general statute relating to uninsured motorist coverage in liability insurance policies did not apply to the coverage document issued to Anderson County; and (2) therefore, under the terms of the coverage document, Harris was excluded from uninsured motorist coverage as an employee and a person who received workers’ compensation benefits. The Supreme Court affirmed, holding that because the coverage document TRMT issued to the County specifically excluded employees and those who receive workers’ compensation benefits from uninsured motorist coverage, and because TRMT was not otherwise required to offer such coverage, Plaintiffs could not recover from TRMT. View "Harris v. Haynes" on Justia Law

Employee suffered bilateral shoulder injuries and underwent separate surgeries on each shoulder. Employee later agreed to a voluntary buyout of his employment. Employee subsequently filed two separate suits for workers’ compensation benefits. The trial court determined that Employee’s permanent partial disability benefits were not capped at one and one-half times the impairment rating and awarded ninety percent permanent partial disability benefits. Employer appealed. A Special Workers’ Compensation Appeals Panel modified the award of permanent partial disability benefits to 37.5 percent as capped at one and one-half times the impairment rating, concluding that Employee’s decision to accept the buyout was not “reasonable” for purposes of the statutory cap. The Supreme Court reversed in part and reinstated the judgment of the trial court as to the award of ninety percent permanent partial disability benefits, holding that because Employee acted reasonably by accepting the voluntary buyout for reasons related to his work injuries, the award for permanent partial disability was not subject to the one-and-one-half-times multiplier. View "Yang v. Nissan N. Am., Inc." on Justia Law

Employee worked for Employer from 1977 through the date of the trial of this matter. Employee began having problems with his arms and hands in 2005. In 2009, Employee had carpal tunnel release surgery performed on his arms. Employee began having problems with his right thumb shortly after his surgeries. A surgical procedure to release the thumb was performed in 2010. In 2013, the trial court awarded permanent partial disability benefits to Employee but ruled that Employee’s injury should be apportioned to the arm, which was subject to an impairment “cap.” Employee appealed, arguing that the award should have been apportioned to the thumb, which was not subject to the cap. The Supreme Court affirmed, concluding that the trial court correctly chose to apportion Employee’s injury to the arm. View "Evans v. Fidelity & Guar. Ins. Co. " on Justia Law

Plaintiff was the minor beneficiary of a $100,000 life insurance policy. Plaintiff filed a complaint against his financial guardian and the insurance company after the guardian misappropriated the insurance proceeds. The trial court entered judgments in favor of Plaintiff. The insurance company appealed. The court of appeals affirmed, concluding that, by entrusting the proceeds to the guardian, the insurance company breached its contractual duties. The Supreme Court reversed, holding (1) the insurance company acted in good faith when it relied upon the validity of a juvenile court order establishing a financial guardianship in making payment of the life insurance proceeds, and (2) therefore, the insurance company could not be liable for breach of contract. View "Hood v. Jenkins" on Justia Law

Employee injured his back while working for Employer. Employee and the Department of Labor and Workforce Development (Department) agreed upon a settlement that provided for a lump sum payment to Employer for his injuries. The settlement and SD-1 form were signed by Employee and both parties' attorneys. Two years later, Employee filed a petition to set aside the settlement. The trial court granted Employee's petition. The Special Workers' Compensation Appeals Panel vacated the trial court's judgment on a procedural issue, finding the SD-1 form was not "fully completed." The Supreme Court reversed the judgments of the Panel and of the trial court and dismissed Employee's petition, holding (1) when the Department approves a settlement, it implicitly approves the accompanying SD-1 form, and a court has no authority to set the settlement aside based on its independent finding that the SD-1 form was not "fully completed"; and (2) the evidence preponderated against the trial court's finding that Employee was not represented by counsel, and the court erred in granting relief based on Tenn. R. Civ. P. 60.02(5) as well as its inherent authority. View "Furlough v. Spherion Atlantic Workforce, LLC" 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

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

In these consolidated cases, the primary issue was whether there was liability insurance coverage for Plaintiffs' injuries resulting from an altercation on the premises of Insured's bar and restaurant. Insurer denied coverage and declined to defend Insured based on its determination that there was no coverage under the terms of the policy. The trial court entered an order finding that the altercation was covered under both the commercial general liability and liquor liability provisions of the policy. The court of appeals ruled that the liquor liability coverage agreement provided coverage for the judgments but that the commercial general liability agreement provided no coverage. The Supreme Court reversed, holding (1) based on the clear terms of the policy agreement, there was no liability coverage because the incident arose from an assault and battery, which was an excluded cause, and because there was no nonexcluded concurrent cause to provide coverage; and (2) estoppel by judgment did not apply to collaterally estop Insurer from arguing the lack of coverage. View "Clark v. Sputniks, LLC" on Justia Law

After an automobile accident between Insured's van and a motorcycle, Insurer filed a declaratory judgment action to determine whether the van was covered under a commercial policy or a personal policy with lower liability limits. Insurer alleged that before the accident Insured had instructed his insurance agent to transfer the van from the commercial policy to the personal policy. Insured denied this and alleged that he had instructed the agent to retain the van on the commercial policy. The trial court ruled that because Insurer had sent Insured a letter and premium bills showing the change in coverage and Insured had paid the bills without objection, Insured had ratified the transfer and the van was covered under the personal policy. The court of appeals reversed. The Supreme Court affirmed the court of appeals but on different grounds, holding (1) the action of the insurance agent in transferring the van to the personal policy was not subject to ratification by Insured because the insurance agent was not acting in Insured's stead or for his benefit when it made the transfer; and (2) Insurer was estopped from denying coverage under the commercial policy. View "Allstate Ins. Co. v. Tarrant" on Justia Law