Justia Tennessee Supreme Court Opinion Summaries

Petitioner Henry Felts was convicted of aggravated burglary and attempted murder. Petitioner filed a petition for post-conviction relief, alleging ineffective assistance of counsel. The post-conviction court vacated Petitioner's conviction, finding that trial counsel's representation was ineffective because he (1) failed to pursue the defense of attempted voluntary manslaughter and (2) advised Petitioner not to testify when he had promised the jury that Petitioner would testify. The court of criminal appeals affirmed. The Supreme Court reversed, holding that the courts below erred in finding trial counsel's performance deficient where (1) trial counsel chose a single, reasonable defense theory to the exclusion of another plausible, but inconsistent theory; and (2) trial counsel's decision not to call Petitioner as a witness was consistent with his altered trial strategy. View "Felts v. State" on Justia Law

Defendant contractor entered into a contract to replace a roof. When the newly installed roof developed leaks, Defendant hired an independent contractor to make repairs. While performing the work, the independent contractor caused a fire, resulting in a large insurance claim by the homeowners. As subrogor to the homeowners' rights and claims arising out of the fire, Plaintiff insurance company sued Defendant in tort and contract. The trial court granted Defendant's motion for summary judgment on all claims, finding that because Defendant had subcontracted the work, he could not be liable. The court of appeals reversed. The Supreme Court affirmed, holding that Defendant had an implied non-delegable duty to install the roof in a careful, skillful, diligent, and workmanlike manner. Remanded. View "Fed. Ins. Co. v. Winters " on Justia Law

In this workers' compensation case, Employee was operating a torque gun, which jerked and twisted her right hand while at work. Employee contended that her injury extended into her arm. Employer agreed the injury was compensable but argued that the injury was limited to Employee's index finger. The trial court found that Employee's injury was properly apportioned to her right arm, rather than to her hand or finger, and awarded seventy percent permanent partial disability (PPD) to the right arm. Employer appealed, arguing that the trial court erred by apportioning the injury to the arm and that the award of PPD benefits was excessive. The Supreme Court Special Workers' Compensation Appeals Panel affirmed, holding (1) the evidence did not preponderate against the trial court's decision to apportion Employee's injury to the arm; and (2) the evidence supported the trial court's award of disability benefits. View "Majors v. Randstad Inhouse Servs., L.P." on Justia Law

Defendant Christopher Davis was convicted of aggravated robbery, carjacking, attempt to commit especially aggravated kidnapping, and attempt to commit first degree murder. The court of criminal appeals affirmed the convictions. On appeal, Defendant challenged (1) the legality of the stop of a vehicle in which he was a passenger that led to his arrest; and (2) the sufficiency of the evidence to support his conviction for attempt to commit first degree murder. The Supreme Court affirmed, holding (1) reasonable suspicion existed to permit law enforcement officers to conduct a brief investigatory stop of the car in which Defendant was a passenger; and (2) there was sufficient evidence for the jury to conclude that Defendant and his fellow perpetrator planned and intended to kill the victim, and that Defendant's conduct, considered in light of the totality of the circumstances, constituted a substantial step sufficient to support a conviction for attempted murder. View "State v. Davis" on Justia Law

Employee, hired as a university professor and department head, filed suit against Employer after Employee was removed as department head, alleging a violation of the Tennessee Public Protection Act (TPPA), commonly termed the Whistleblower Statute. Employer filed a motion for judgment on the pleadings, asserting that Employee failed to state a claim for relief under the TPPA. The trial court granted the motion and dismissed the TPPA claim, ruling that, assuming the facts of the complaint to be true, Employee was neither discharged from his employment nor did he refuse to participate in or remain silent about any alleged illegal activities. The court of appeals affirmed. The Supreme Court affirmed the trial court's dismissal of Employee's complaint, holding that because Employee was neither terminated nor discharged from his employment, only removed as department head, the complaint did not allege facts from which the Court could reasonably infer a claim under the TPPA. View "Harman v. Univ. of Tenn" on Justia Law

A trial court granted Wife's petition for divorce from Husband. The trial court divided the parties' real and personal property, declined to award spousal support of any type to either party, and denied a request made by both parties that they be awarded attorney's fees and expenses. The court of appeals (1) affirmed the trial court's division of the marital estate; (2) reversed the trial court's judgment regarding spousal support and ordered Husband to pay Wife alimony in the amount of $1,250 per month until her death or remarriage; and (3) awarded Wife her attorney's fees and expenses. The Supreme Court reversed and reinstated the trial court's judgment, holding that the award of alimony and the award of attorney's fees and expenses was inappropriate in this case, and Wife failed to demonstrate that transitional alimony was appropriate. View "Gonsewski v. Gonsewski" on Justia Law

Defendant was indicted for a murder that occurred nearly ten years prior to his arrest. Defendant's theory of the case implicated two other men, who had previously been tried and acquitted of the murder, as the individuals responsible for the murder. Over the objection of Defendant, the State introduced evidence of the prior acquittals of the other men. A jury convicted Defendant of facilitation of first degree murder. The court of criminal appeals reversed, holding that the evidence of the acquittals of the other parties was irrelevant and that the erroneous admission of the evidence was not harmless. The Supreme Court affirmed, holding (1) under the facts of this case, the evidence of a prior acquittal of an individual for the crime for which the defendant is on trial is not relevant as context evidence, relevant to the credibility of the witness, or relevant to rebut a defense theory that the other individual committed the crime; and (2) the erroneous admission of the evidence was not harmless. Remanded for a new trial. View "State v. Turner" on Justia Law

The Tennessee Board of Medical Examiners suspended Dr. Joseph Rich's medical license for one year and imposed other conditions after finding that, among other things, the physician had violated Tenn. Code Ann. 63-6-214(b)(1)(4) and (12). The chancery court affirmed the Board's judgment. The court of appeals reversed because the Board failed to articulate the applicable standard of care in its deliberations. The Supreme Court (1) held that the Board was required by Tenn. Code Ann. 63-6-214(g) to articulate the applicable standard of care in its deliberations; (2) vacated the ruling of the trial court to the extent that it affirmed the Board's decision that Rich had violated sections 63-6-214(b)(1)(4) and (12); (3) vacated the judgment of the court of appeals to the extent it reversed the Board's findings that Rich violated sections 63-6-214(b)(1)(4) and (12); and (4) rather than reversing the Board's findings of violations, remanded the matter to the Board with instructions to conduct deliberations based on the existing record and articulate the applicable standard of care as required by the statute. View "Rich v. Tenn. Bd. of Med. Exam'rs" on Justia Law

After a jury trial, Defendant Joshua Parker was convicted of second degree murder and attempted rape. The court of criminal appeals affirmed. The Supreme Court affirmed Defendant's conviction of attempt to commit rape but reversed and vacated Defendant's conviction of second degree murder, holding (1) there was insufficient evidence to support Defendant's conviction, (2) State v. Mellons did not control the outcome of this case, (3) sufficient proof must support every element of the offense of which a defendant is convicted, even where the conviction offense is charged as a lesser-included offense and sufficient proof supports the greater offense, and (4) the trial court erred in charging the jury with second degree murder as a lesser-included offense of first degree felony murder. Because the proof was sufficient to support the offense of reckless homicide, remanded for entry of an amended judgment reflecting a conviction of reckless homicide and sentencing on reckless homicide. View "State v. Parker" on Justia Law

A father and his sixteen-year-old son were sued after the son was involved in an accident while driving a vehicle owned, insured, and provided to him by his father. The basis for the suit against the father was the family purpose doctrine, which imposes vicarious liability on the owner of a vehicle for the negligent operation of the vehicle by a family member. The trial court granted summary judgment to the father, finding that the family purpose doctrine did not apply. The court of appeals reversed and granted partial summary judgment in favor of the plaintiff, ruling that the family purpose doctrine applied as a matter of law. The Supreme Court vacated the decision of the court of appeals, holding that while two of the essential elements of the family purpose doctrine were met in this case, a genuine issue of material fact remained as to the last element. Remanded for trial. View "Starr v. Hill" on Justia Law