Justia Tennessee Supreme Court Opinion Summaries

Jo Carol Edwards was employed as a truck driver by Peoplease, LLC. On August 14, 2020, while working, she was involved in a motor vehicle accident that caused her knees to strike the dashboard, resulting in knee pain and injuries. Ms. Edwards was subsequently diagnosed with severe, pre-existing arthritis in both knees. However, medical experts disagreed on whether her need for knee replacement surgery and resulting disability were caused by an aggravation of her pre-existing condition due to the work accident or were solely attributable to the underlying arthritis. Ms. Edwards claimed workers’ compensation benefits for her knee injuries, arguing that the accident aggravated her arthritis and led to her symptoms and need for surgery.The Court of Workers’ Compensation Claims credited Ms. Edwards’ testimony that she was asymptomatic prior to the accident and found that her work-related accident aggravated her pre-existing arthritis, resulting in compensable knee injuries. The court ordered Peoplease to pay for her medical expenses, disability benefits, and related costs. On interlocutory appeal, the Workers’ Compensation Appeals Board partially affirmed but ultimately reversed the award on remand, finding that Ms. Edwards failed to overcome the presumption in favor of her treating physician’s opinion that the accident was not the primary cause of her need for surgery and disability.The Supreme Court of Tennessee reviewed the case. It clarified that factual findings in workers’ compensation cases are reviewed de novo on the record with a presumption of correctness unless the preponderance of the evidence indicates otherwise, regardless of whether the findings are based on live or deposition testimony. The court further held that an aggravation injury under Tennessee law does not require a permanent change to be compensable; it is sufficient if the aggravation primarily arises out of employment and contributes more than fifty percent to the need for medical treatment or disability. Applying this standard, the Supreme Court reversed the Appeals Board’s decision and reinstated the Trial Court’s award of benefits to Ms. Edwards. View "Edwards v. Peoplease, LLC" on Justia Law

Brian Coblentz was employed as a sales representative for Stanley National Hardware, a vendor supplying hardware products to retail stores, including Tractor Supply Company. His duties involved visiting Tractor Supply stores, checking inventory, placing orders, and maintaining the appearance of Stanley National product displays. During a visit to a Fayetteville, Tennessee Tractor Supply store, Coblentz was injured when a barn door track from a Stanley National display fell on him. Stanley National paid him workers’ compensation benefits. Coblentz and his wife then sued Tractor Supply, alleging negligence in maintaining the display and failing to warn about potential hazards.The Circuit Court for Lincoln County granted summary judgment for Tractor Supply. It found Tractor Supply to be Coblentz’s “statutory employer” under Tennessee Code Annotated section 50-6-113(a), reasoning that Coblentz’s work was part of Tractor Supply’s regular business. This classification shielded Tractor Supply from tort liability under the exclusive remedy provision of Tennessee’s workers’ compensation statutes. The Tennessee Court of Appeals affirmed, applying the same statutory employer analysis. However, one judge dissented, arguing that the relationship between Stanley National and Tractor Supply was purely vendor-vendee, not principal-subcontractor, and thus should not invoke workers’ compensation protections.On appeal, the Supreme Court of Tennessee reversed the lower courts. It held that the term “subcontractor” in section 50-6-113(a) refers to entities performing labor or services, and does not encompass a pure vendor-vendee relationship involving only the sale and ancillary delivery of goods. Applying a “predominant purpose” test, the Court found the primary purpose of the arrangement was merchandise sales, with additional services being incidental. Therefore, Tractor Supply is not Coblentz’s statutory employer and is not protected by the exclusive remedy provision. The case was remanded for further proceedings. View "Coblentz v. Tractor Supply Company" on Justia Law

An employee working as a practice manager at a healthcare facility in Cleveland, Tennessee, claimed that she contracted COVID-19 in December 2020 through workplace exposure to infected patients and coworkers. She sought workers’ compensation benefits, alleging disabling lung injuries and long-term complications as a result. Initially, the employer paid temporary disability benefits but later denied her request for total disability, relying on the opinion of a pulmonologist who concluded that her exposure to the virus could not be attributed primarily to her workplace given widespread community transmission.The Court of Workers’ Compensation Claims considered the employer’s motion for summary judgment, supported by the pulmonologist’s opinion that workplace exposure could not be established as the primary cause of the illness. The court excluded certain medical evidence offered by the employee and denied her request for a continuance to obtain a new medical expert. It subsequently granted summary judgment for the employer, finding that the employee had failed to present expert medical evidence of causation, an essential element of her claim.On appeal, the Workers’ Compensation Appeals Board affirmed, holding that the employee’s challenge to the denial of a continuance was untimely and that summary judgment was appropriate due to her lack of expert proof on medical causation. The Supreme Court of Tennessee Special Workers’ Compensation Appeals Panel reviewed the case and affirmed the Appeals Board’s judgment. The court held that, where an employee fails to provide expert medical evidence establishing that her injury arose primarily out of her employment, summary judgment for the employer is warranted. The court also found no reversible error in the handling of procedural issues and clarified that earlier case law regarding employer filing obligations did not preclude the employer’s defenses in this context. View "Graham v. CHI Memorial Healthcare System" 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

The case involves a healthcare liability action filed by the plaintiff, Payton Castillo, against CHI Memorial Hospital and other entities and physicians, alleging negligence in the care provided to her husband, who died shortly after being discharged from the hospital's emergency room. The defendants sought a protective order based on the quality improvement committee (QIC) privilege under Tennessee Code Annotated section 68-11-272 to prevent inquiry into a meeting held by the hospital and the decedent's family. The trial court denied the defendants' motion.The Hamilton County Circuit Court initially reviewed the case and denied the defendants' motion for a protective order, finding that statements made during the meeting were not protected by the QIC privilege. The defendants appealed, and the Court of Appeals affirmed the trial court's decision, concluding that the statements made in the meeting were not protected by the QIC privilege.The Supreme Court of Tennessee reviewed the case and held that the QIC privilege applied to statements made during the meeting that were based on information obtained during the QIC process. However, the court found that Memorial waived the privilege when hospital management voluntarily disclosed the privileged information during the meeting with Mrs. Castillo. The court affirmed the judgment of the Court of Appeals on separate grounds and remanded the case to the trial court for further proceedings consistent with its opinion. View "Castillo v. Rex" 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

Robert Trentham slipped and fell on a pedestrian bridge at the Venue at Cool Springs apartment complex in Franklin, Tennessee, owned by Mid-America Apartments, LP (MAA). The incident occurred on a rainy morning, and Trentham sustained serious injuries. He filed a premises-liability lawsuit against MAA, alleging negligence in maintaining the bridge, which he claimed had microbial growth that caused his fall.The Circuit Court for Williamson County found in favor of Trentham, determining that MAA was on constructive notice of the dangerous condition due to the microbial growth. The court concluded that MAA had breached its duty of care and awarded Trentham damages. MAA appealed the decision, arguing that it was not on constructive notice of the dangerous condition.The Court of Appeals affirmed the trial court's decision, agreeing that the evidence supported the finding that MAA was on constructive notice of the microbial growth on the bridge. The appellate court upheld the trial court's conclusions regarding MAA's duty, breach, and the resulting damages.The Supreme Court of Tennessee reviewed the case and held that MAA was on constructive notice of the dangerous condition on the pedestrian bridge. The court referenced Blair v. West Town Mall, which allows for constructive notice to be established by showing a pattern of conduct, a recurring incident, or a general or continuing condition. The court found that the microbial growth on the bridge constituted a general or continuing condition, making it reasonably foreseeable to MAA. Consequently, the Supreme Court affirmed the decisions of the lower courts, holding that MAA breached its duty of care to Trentham. View "Trentham v. Mid-America Apartments, LP" 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

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