Justia Tennessee Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals affirming the trial court's dismissal of Plaintiffs' action seeking a declaratory judgment concerning the rights and obligations of the parties under a 2001 contract, holding that the court of appeals erred in concluding that dismissal was appropriate on the grounds that the complaint was barred by the doctrine of res judicata.In a previously filed action, Plaintiffs sought similar relief, but the case was dismissed for failure to exhaust administrative remedies. In the instant case, the trial court granted Defendants' motions to dismiss, finding that Plaintiffs lacked standing. The court of appeals affirmed on other grounds, concluding that res judicata barred the complaint and, as such, declined to address the standing issue. The Supreme Court reversed, holding that dismissal of the previous case did not constitute an adjudication on the merits for purposes of res judicata. The Court then remanded the case to the court of appeals for consideration of the standing issue. View "Elvis Presley Enterprises, Inc. v. City of Memphis" on Justia Law

The Supreme Court reversed the judgment of the court of criminal appeals dismissing Defendant's appeal and dismissed Defendant's convictions for possession with the intent to deliver more than twenty-six grams of methamphetamine and possession of drug paraphernalia, holding that the initial search of Defendant's house during which law enforcement discovered illegal contraband was unlawful.Defendant pled guilty but specifically reserved a certified question of law pertaining to the legality of the search in this case. The court of criminal appeals dismissed the appeal, determining that the certified question was not dispositive because the evidence would have been admissible notwithstanding the search in question under the inevitable discovery doctrine. The Supreme Court reversed and dismissed Defendant's convictions, holding (1) the inevitable discovery doctrine did not apply in this case; and (2) the State did not carry its burden of proving that either exigent circumstances or voluntary consent justified their warrantless search of Defendant's home. View "State v. Scott" on Justia Law

In this parental termination case, the Supreme Court reversed the judgment of the trial court terminating Father's parental rights, holding that the trial court misapplied the missing witness rule and in applying the doctrine of unclean hands to Father and that the evidence of abandonment was not clear and convincing.The trial court terminated Father's parental rights based on a finding of abandonment by willful failure to support, willful failure to make reasonable or consistent support payments, and willful failure to visit and further found that termination was in the child's best interests. In reaching its conclusions, the trial court applied the missing witness rule and the doctrine of unclean hands. The court of appeals reversed, concluding, among other things, that the trial court erred by applying the missing witness rule in a non-jury trial. The Supreme Court affirmed the court of appeals' judgment with the exception of its holding on the missing witness rule, holding (1) while the missing witness rule may apply in a non-jury trial, the trial court misapplied the rule in this case; (2) the trial court erred in applying the doctrine of unclean hands to Father; and (3) there was not clear and convincing evidence that Father abandoned the child. View "In re Mattie L." on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of criminal appeals affirming Defendant's convictions for two counts of delivering marijuana and two counts of money laundering, holding that the evidence was insufficient to support one of the money laundering convictions.Specifically, the Supreme Court held (1) the evidence supporting the first money laundering conviction was legally sufficient; (2) the evidence was insufficient with respect to the second money laundering conviction; (3) Defendant's punishment for both delivery of marijuana and money laundering does not violate double jeopardy protections; and (4) the money laundering statute is not unconstitutionally vague by virtue of its use of the undefined phrase "carrying on." View "State v. Allison" on Justia Law

The Supreme Court held that a claim for wrongful termination of employment could not be asserted under the Teacher Tenure Act, Tenn. Code Ann. 49-5-501 to -515, by classifying a tenured teacher's resignation as a constructive discharge rather than a voluntary quit.After Plaintiff, a tenured teacher, quit her teaching position she sued for wrongful termination under the Teacher Tenure Act, alleging that she was constructively discharged. The amended complaint also asserted other claims. The trial court granted summary judgment against Plaintiff. The appellate court reversed the trial court's dismissal of Plaintiff's wrongful discharge claim under the Act, concluding that the doctrine of constructive discharge could give rise to a wrongful termination claim under the Act. The court of appeals otherwise affirmed the trial court. The Supreme Court reversed in part, holding (1) constructive discharge is not applicable to wrongful termination claims under the Act; and (2) the lower courts properly dismissed Plaintiff's remaining claims. View "Lemon v. Williamson County Schools" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the trial court's grant of summary judgment to the manufacturers of certain equipment (Equipment Defendants) in this product liability action, holding that, on the facts and applicable law, the Equipment Defendants had no duty to warn of the dangers associated with the post-sale integration of asbestos-containing materials manufactured and sold by others.Plaintiffs asserted claims against the Equipment Defendants under the Tennessee Products Liability Act, Tenn. Code Ann. 29-28-101 through -108, for failing to warn of the dangers of exposure to asbestos-containing products that the Equipment Defendants did not manufacture or sell. The trial court granted summary judgment in favor of the Equipment Defendants. The court of appeals reversed, holding that the Equipment Defendants owed a common law duty to warn about the post-sale integration of asbestos-containing products manufactured and sold by others. The Supreme Court reversed, holding that, under the language of the Act, the Equipment Defendants could not be held liable for injuries resulting from products that they did not make, distribute, or sell. View "Coffman v. Armstrong International, Inc." on Justia Law

The Supreme Court held that the seven District Attorneys General who sued several drug companies under the Tennessee Drug Dealer Liability Act lacked standing and that the two Baby Doe plaintiffs who sued under the Act and alleged facts showing that the drug companies knowingly participated in the illegal drug market by facilitating the marketing or distribution of opioids stated a claim against the drug companies under the Act.The District Attorneys and the Baby Doe plaintiffs brought this action alleging that the defendant drug companies knowingly participated in the illegal drug market by intentionally flooding East Tennessee communities with prescription opioid medications. The Baby Doe plaintiffs alleged that they were harmed by exposure to opioids in utero and the District Attorneys claimed that the opioid epidemic had damaged the communities in their districts. The trial court dismissed the case, ruling that the Act did not apply. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) the District Attorneys lacked standing to bring an action under the Act as individual plaintiffs; and (2) the Baby Doe plaintiffs stated a claim against the drug companies based on allegations of intentional and purposeful participation in the illegal opioid market. View "Effler v. Purdue Pharma L.P." on Justia Law

The Supreme Court reinstated the trial court's judgment terminating Mother's parental rights on the basis of the statutory factor enumerated in Tenn. Code Ann. 36-1-113(g)(14), holding that the statute is ambiguous and that In re Ayden S., No. M2017-01185-COA-R3- PT, 2018 WL 2447044, 7 (Tenn. Ct. App. May 31, 2018), is overruled.Section 36-1-113(g)(14) requires a person seeking termination of parental rights to prove by clear and convincing evidence that a "parent or guardian has failed to manifest, by act or omission, an ability and willingness to personally assume legal and physical custody or financial responsibility of the child." In In re Ayden S., the court of appeals interpreted this language as requiring proof that a parent was both unable and unwilling personally to assume legal and physical custody or financial responsibility of a child. In In re Amynn K., No. E2017-01866-COA- R3-PT, 2018 WL 3058280, 14 (Tenn. Ct. App. June 20, 2018), the court of appeals construed the statute as requiring proof that a parent was either unable or unwilling to personally assume legal and physical custody or financial responsibility of a child. The Supreme Court held that the In re Amynn K. interpretation best effectuated legislative intent and thus reversed. View "In re Neveah M." on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the trial court's grant of summary judgment for an insurance agent on Plaintiffs' claim that the insurance agent negligently failed to procure excess uninsured motorist coverage in accordance with Plaintiffs' instructions, holding that Tenn. Code Ann. 56-7-135(b) applies to create a rebuttable presumption in actions against an insurance agent for negligent failure to procure an insurance policy as directed.In granting summary judgment for the insurance agent, the trial court concluded that Plaintiffs had failed to rebut the statutory presumption that they had accepted the provided coverage, which did not include excess uninsured motorist coverage. The court of appeals reversed, determining that the rebuttable presumption in section 56-7-135(b) does not apply to actions against an insurance agent. The Supreme Court reversed, holding (1) the rebuttable presumption articulated in section 56-7-135(b) applies to actions against an insurance agent by insureds under the insurance policy for negligent failure to procure an insurance policy as directed; and (2) Plaintiffs failed to rebut the statutory presumption in this case. View "Parveen v. ACG South Insurance Agency, LLC" on Justia Law

The Supreme Court reversed the decision of the Court of Criminal Appeals reversing the trial judge's denial of Defendant's motion for recusal, holding that, for the reasons provided today in State v. Griffin, __ S.W.3d __ (Tenn. 2020), Defendant failed to establish that there was a reasonable basis to question the trial judge's impartiality.In this case, one of three decided today involving a trial judge who previously served as a deputy district attorney general in Knox County at the time the defendants in each case were indicted by the Knox County Grand Jury, Defendant moved for recusal, arguing that the trial judge previously had supervisory authority over his case as Deputy District Attorney General. The trial judge denied the motion for recusal, but the Court of Criminal Appeals reversed. The Supreme Court reversed, holding that, as in Griffin, Defendant failed to establish that the trial judge's supervisory responsibilities in his role as Deputy District Attorney General were personal or substantial in that case. View "State v. Clark" on Justia Law