Justia Tennessee Supreme Court Opinion Summaries

Plaintiff contracted to sell Defendants certain real property. The contract provided that Plaintiff would retain ownership of a sixty-foot wide strip of property to provide access to her remaining property, but the warranty deed failed to include the reservation. When it became difficult for Plaintiff to access her property due to improvements on the purchased real property, Plaintiff sued Defendants, alleging, among other claims that were subsequently dismissed, breach of contract. The trial court ruled for Plaintiff on the breach of contract claim and awarded her $650,000 in damages. The Court of Appeals reversed, concluding that the gravamen of Plaintiff’s prevailing claim was injury to real property, and therefore, the claim was barred by the three-year statute of limitations applicable to “actions for injuries to personal or real property.” The Supreme Court reversed, holding that Plaintiff’s claim was not barred by the three-year statute of limitations because the gravamen of Plaintiff’s prevailing claim was breach of contract, to which the six-year statute of limitations for “actions on contracts not otherwise expressly provided for” applied. View "Benz-Elliott v. Barrett Enters., LP" on Justia Law

Property Owners filed an action against Montgomery County, asserting a claim of regulatory taking under Tenn. Const. art. I, 21, for which they sought compensation pursuant to the inverse condemnation statute. The County filed a motion to dismiss for failure to state a claim. The trial court denied the motion. The Court of Appeals reversed in part and remanded, holding (1) the Property Owners’ regulatory takings claim should be dismissed because the Court had not yet recognized regulatory takings under the state Constitution; but (2) the Property Owners alleged facts sufficient to state a claim for inverse condemnation. The Supreme Court reversed the Court of Appeals’ judgment insofar as it reversed the trial court’s judgment and dismissed the Property Owners’ regulatory taking claim, holding (1) like the Takings Clause of the federal Constitution, Tenn. Const. art. I, 21 encompasses regulatory takings; and (2) the Property Owners’ complaint was sufficient to allege a state constitutional regulatory taking claim, for which they may seek compensation under Tennessee’s inverse condemnation statute. View "Phillips v. Montgomery County" on Justia Law

Landlords brought an unlawful detainer action against Tenants to regain possession of the premises and recoup damages. The general sessions court later entered a default judgment granting Landlords possession of the property and a $42,500 judgment for past due rent and attorneys' fees. Tenants filed a notice of appeal and posted an appeal bond by depositing $250 cash with the clerk of court. Landlords filed a motion to dismiss, arguing that Tenants violated Tenn. Code Ann. 29-18-130(b)(2) by failing to post a bond equal to one year's rent. The circuit court denied the motion, concluding that a bond for one year's rent was unnecessary because Tenants had already surrendered possession of the property and vacated the premises. The Supreme Court affirmed the circuit court's denial of Landlords' motion to dismiss, holding that the circuit court did not err in determining that section 29-18-130(b)(2) does not require a tenant who has surrendered possession of the property to post a bond for one year's rent when appealing an adverse judgment of the general sessions court in an unlawful detainer action. View "Johnson v. Hopkins" on Justia Law

After the death of the president of the original corporate developer of a residential development, a successor developer purchased the property with the intent to continue to develop it. Homeowners filed suit, alleging the successor developer's new development plan violated restrictive covenants. The court of appeals remanded on the question of whether a general plan of development, or the plat for the subdivision, gave rise to certain implied restrictive covenants. Meanwhile, the homeowners' association amended its charter and the restrictive covenants, which the homeowners challenged. The trial court granted the successor developer summary judgment on all claims in both suits. The court of appeals remanded with directions to determine whether the amendments were reasonable and whether the plat supported the existence of implied restrictive covenants. The successor developer appealed, contending that Tennessee law did not support the court of appeals' reasonableness inquiry and that the plat provided no basis for the existence of implied restrictive covenants. The Supreme Court held that the amendments were properly adopted but found that there was no basis for implied restrictive covenants arising from a general plan of development or from the plat, thus vacating the portion of the court of appeals' judgment remanding the case.View "Hughes v. New Life Dev. Corp." on Justia Law

Jefferson County enacted a comprehensive zoning ordinance limiting the use of certain property, including Plaintiff's property, to agricultural purposes. Before the passage of the ordinance, Plaintiff undertook various activities designed to establish business operations for its property. When the County issued a stop work order, Plaintiff, without first receiving a decision from the County's board of zoning appeals, filed a declaratory judgment action arguing that the portion of the property not previously subject to zoning qualified as a pre-existing non-conforming use. The trial court (1) concluded Plaintiff was not required to exhaust its administrative remedies, and (2) ruled that the business activities on the property qualified for protection under Tenn. Code Ann. 31-7-208. The court of appeals set the judgment aside, holding that Plaintiff had failed to exhaust its administrative remedies. The Supreme Court reversed and reinstated the judgment of the trial court, holding (1) the trial court did not err by ruling that Plaintiff was not required to exhaust the administrative remedies; and (2) the evidence did not preponderate against the trial court's finding that Plaintiff had established operations sufficient to qualify for protection under section 13-7-208. View "Ready Mix, USA, LLC v. Jefferson County" on Justia Law

After Decedent's will was admitted to probate in the probate court, the Bureau of TennCare filed a claim against her estate seeking reimbursement for services provided through the TennCare program. Decedent's personal representative filed an exception to this claim. The probate court upheld TennCare's claim, and the Estate appealed. The circuit court determined that Decedent's real property was not subject to TennCare's claim. TennCare appealed. The court of appeals vacated the circuit court's judgment and affirmed the probate court, holding that the circuit court lacked subject matter jurisdiction over the appeal from the probate court and that the appeal should have been filed with the court of appeals. The Supreme Court affirmed, holding (1) the circuit court lacked jurisdiction over the Estate's appeal from the probate court's judgment regarding TennCare's claim; and (2) the real property owned by Decedent at the time of her death was subject to TennCare's claims for reimbursement. View "In re Estate of Trigg " on Justia Law

Regent Investments sued Earline Waddle and Lorene Elrod alleging that Regent contracted to purchase real property from Waddle, but that afterwards Regent discovered Waddle had conveyed one-half of her interest in the property to Elrod. Waddle filed a cross-claim against Elrod, alleging that Elrod had acquired her interest in the property through undue influence. Regent later dismissed its claims. Waddle subsequently agreed to settle the case against Elrod by way of emails sent by the parties' attorneys. Elrod, however, refused to sign the settlement documents. The trial court entered an order enforcing the settlement agreement. Elrod appealed, arguing that the Statue of Frauds precluded enforcement of the settlement agreement. The court of appeals affirmed, reasoning that the Statute of Frauds applies only to contracts for the sale of lands. The Supreme Court affirmed on alternate grounds, holding (1) the Statute of Frauds applies to settlement agreements requiring the transfer of an interest in real property; but (2) the Statute of Frauds did not bar enforcement of the settlement agreement at issue in this appeal because the emails that the parties' counsel exchanged and the legal description of the property included in the cross claim satisfied the Statute of Frauds. View "Waddle v. Elrod" on Justia Law