Justia Tennessee Supreme Court Opinion Summaries

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

After an investigatory stop and frisk, Defendant was charged with the unlawful possession of a handgun after a felony conviction and the unlawful possession of a handgun while under the influence of alcohol and was convicted on both counts. Defendant appealed, arguing that his motion to suppress evidence should have been granted. The court of criminal appeals affirmed. The Supreme Court reversed the judgments of conviction and dismissed the cause, holding that because the investigatory stop and frisk of Defendant was not supported by specific and articulable facts establishing reasonable suspicion that a criminal act was being or about to be committed, the trial court erred by failing to suppress the handgun found by the police and presented as evidence at trial. View "State v. Williamson" 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

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

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 "Gamble v. Sputniks, LLC" on Justia Law

Defendant was tried and convicted of two counts of first degree murder and sentenced to death for each offense. The court of criminal appeals affirmed. The Supreme court affirmed in part and reversed in part, holding (1) the trial court erred by admitting detailed evidence of a prior claim of child sex abuse and by allowing references to Defendant's refusal to submit to a polygraph examination; (2) the prosecutor committed misconduct during the opening statement and during the final arguments of both the guilty and penalty phases of the trial; (3) however, the errors were harmless, and therefore, the convictions were affirmed; but (4) because certain of the inadmissible evidence was particularly inflammatory and the prosecution made several inappropriate comments, the sentences of death must be set aside. Remanded for new sentencing hearings. View "State v. Sexton" on Justia Law

At issue in this appeal was the procedure an inmate must follow to dispute the determination of parole eligibility when the inmate is serving consecutive determinate sentences imposed pursuant to the Criminal Sentencing Reform Act. Under the Uniform Administrative Procedures Act (UAPA), which governs an inmate's challenge to the Tennessee Department of Correction's (TDOC) calculation of a release eligibility date, an inmate must request a declaratory order from the TDOC before filing a declaratory action in court. Petitioner petitioned for a writ of certiorari naming the Board of Probation and Parole and TDOC. The trial court dismissed the petition. The Supreme Court affirmed the trial court, holding (1) because Petitioner failed to seek a declaratory order from TDOC, the trial court properly dismissed his petition naming TDOC and its officials; and (2) the UAPA does not govern an inmate's challenge to a decision of the Board concerning parole, and therefore, the trial court properly granted the Board's and its officials' motions to dismiss because the allegations of the petition failed to state a claim upon which relief could be granted. View "Stewart v. Schofield" on Justia Law

The trial court awarded workers' compensation benefits to an injured lineman who had violated a rule requiring the use of protective gloves while in a bucket lift. The employer appealed, contending that the statutory defenses of willful misconduct and, more particularly, the willful failure or refusal to use a safety appliance or device precluded recovery. The Supreme Court reversed the judgment of the trial court and dismissed the case, holding that because the evidence established that the employee admitted his knowledge of a regularly enforced safety rule, understood the rationale for the rule, and willfully failed to comply, the injuries he suffered because of the rule violation were not compensable. View "Mitchell v. Fayetteville Pub. Utils." on Justia Law