Justia Tennessee Supreme Court Opinion Summaries

A pregnant patient was admitted to a medical center, where she suffered an anaphylactic reaction to medication administered for a streptococcus infection. Her treating physician and hospital staff provided various treatments but did not administer epinephrine, a standard treatment for anaphylaxis. The patient’s child was born with severe brain injuries, which the plaintiff alleged were caused by the anaphylactic episode and the defendants’ failure to use epinephrine. The plaintiff sued the physician and medical entities for healthcare liability, contending that the physician’s decision not to use epinephrine fell below the standard of care and that the hospital staff was negligent in monitoring.After an initial trial ended in a defense verdict but was set aside due to evidentiary errors, a second jury trial again resulted in a verdict for the defendants. Following the second trial, it was discovered that a juror had, during deliberations, conducted personal research by reading an EpiPen warning label at home and shared its contents with the other jurors. The plaintiff moved for a new trial, arguing this extraneous information affected the verdict. The Circuit Court for Knox County denied the motion, ruling the plaintiff had not proven by clear and convincing evidence that the jury was influenced by the information.On appeal, the Tennessee Court of Appeals reversed, holding the trial court had applied the wrong legal standard and that prejudice should be presumed when jurors are exposed to extraneous, material information. The defendants then sought review.The Supreme Court of Tennessee held that, in civil cases involving the constitutional right to a jury trial, courts must use a burden-shifting framework: the party challenging a verdict must first prove by a preponderance of the evidence that the jury was exposed to material extraneous information, which triggers a rebuttable presumption of prejudice. The party defending the verdict must then show there is no reasonable possibility the information altered the verdict. The Court vacated the decision of the Court of Appeals and remanded for the trial court to apply this framework. View "Collier ex rel. Chayce C. v. Roussis" on Justia Law

After a motor vehicle accident in Knoxville, Tennessee, a child sustained serious injuries while riding in a booster seat secured with a seatbelt extender. The seatbelt extender, manufactured by Ford Motor Company, was purchased and installed by the child’s father to address difficulties buckling the booster seat in their Nissan Juke. Both the booster seat and the seatbelt extender were not inherently defective for their intended purposes, but the plaintiff alleged that using the two products together created a dangerous condition. The plaintiff filed a product liability action under the Tennessee Products Liability Act, asserting that Ford failed to adequately warn against the risks of using its seatbelt extender in combination with a booster seat.The Circuit Court for Knox County initially granted summary judgment to Dorel Juvenile Group, the booster seat manufacturer, but denied Ford’s motion for summary judgment, finding Ford to be a manufacturer or seller under the Act. After a mistrial in the plaintiff’s claim against Ford, the trial court allowed an interlocutory appeal to address whether the Tennessee Supreme Court’s prior decision in Coffman v. Armstrong International, Inc. required dismissal of the failure-to-warn claims. The Court of Appeals reversed the trial court, holding that Coffman barred the plaintiff’s claims as a matter of law.The Supreme Court of Tennessee reviewed the certified question and clarified that Coffman, which involved post-sale integration of inherently dangerous asbestos-containing materials into a sound product, does not require dismissal as a matter of law of failure-to-warn claims when two independently sound products are used together and create a dangerous condition. The Court reversed the judgment of the Court of Appeals and remanded the case to the trial court for further proceedings, holding that Coffman does not foreclose the plaintiff’s failure-to-warn claims under these circumstances. View "Woodruff v. Ford Motor Co." on Justia Law

A serious automobile accident in Knoxville, Tennessee resulted in the death of Benjamin Woodruff and severe injuries to his six-year-old son, Ethan. At the time of the crash, Ethan was in a high-backed booster seat manufactured by Dorel Juvenile Group and was restrained using a seatbelt extender made by Ford Motor Company, which had been purchased separately to address difficulties in buckling the booster seat in the family’s Nissan Juke. The booster seat’s manual referenced the possible use of a seatbelt extender, while the vehicle’s manual warned against using extenders to install child restraints. After the accident, Sarah Woodruff filed a product liability lawsuit under the Tennessee Products Liability Act, alleging that both Dorel and Ford failed to adequately warn of the dangers of using a seatbelt extender with the booster seat.The Circuit Court for Knox County initially granted summary judgment to Dorel, finding it had no duty to warn about another manufacturer’s product, but denied summary judgment to Ford. After an intervening decision by the Tennessee Supreme Court in Coffman v. Armstrong International, Inc., the trial court vacated its grant of summary judgment to Dorel, then later reinstated it after further motions. The Court of Appeals affirmed the grant of summary judgment for Dorel, holding that Coffman barred the plaintiff’s failure-to-warn claim as a matter of law since Dorel’s product was only allegedly dangerous when used with another manufacturer’s product.The Supreme Court of Tennessee reviewed the case and clarified that its prior holding in Coffman does not mandate dismissal as a matter of law of the plaintiff’s failure-to-warn claim against Dorel. The Court explained that Coffman was limited to situations involving the integration of inherently dangerous components into another product post-sale, and does not foreclose failure-to-warn claims where two sound products together create a risk. The Supreme Court of Tennessee reversed the Court of Appeals and remanded for further proceedings. View "Woodruff ex rel. Woodruff v. Ford Motor Co." on Justia Law

Cinda Haddon was injured in a motor vehicle collision when Ladarius Vanlier, who was uninsured, struck her vehicle. Haddon filed a lawsuit against Vanlier for negligence and, as allowed by Tennessee’s Uninsured Motorist Act, served process on her uninsured motorist insurer, Auto-Owners Insurance Company. Vanlier could not be served, so Haddon proceeded directly against Auto-Owners. The case went to a jury trial, which found Vanlier at fault and awarded Haddon $320,000 in damages for her personal injuries, including pain and suffering, loss of enjoyment of life, permanent injury, and medical expenses.After the jury’s award, Haddon requested prejudgment interest. The Circuit Court for Davidson County denied her request, reasoning that prejudgment interest is not available for personal injury actions under Tennessee law, even though equitable considerations would otherwise support such an award. Haddon appealed. The Court of Appeals for Tennessee reversed, holding that claims against an uninsured motorist carrier sound in contract, not tort, meaning the prohibition on prejudgment interest for personal injury actions did not apply. The Court of Appeals sent the case back to the trial court to determine the amount of prejudgment interest.The Supreme Court of Tennessee reviewed the case and concluded that the action’s gravamen was in personal injury, not contract. The Court determined that Haddon’s claim was based on the tortious conduct of Vanlier and sought damages for personal injuries, rather than any breach of contract by Auto-Owners. As prejudgment interest is not allowed in personal injury actions under Tennessee law, the Supreme Court of Tennessee reversed the Court of Appeals and reinstated the trial court’s judgment denying prejudgment interest. The holding is that prejudgment interest is not available in an action brought against a tortfeasor and defended by an uninsured motorist carrier when the claim’s gravamen is personal injury. View "Haddon v. Vanlier" on Justia Law

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