Justia Tennessee Supreme Court Opinion Summaries

The Supreme Court clarified the procedure circuit courts must follow when an original defendant in general sessions court appeals an adverse general sessions judgment to circuit court but then fails to appear for the de novo circuit court trial to prosecute his appeal, holding that, in the instant case, the circuit court erred in dismissing Appellant's appeal.When Appellant failed to appear in circuit court to prosecute his appeal from an adverse general sessions court judgment the circuit court dismissed the appeal and remanded this case to the general sessions court for execution of the judgment. The court of appeals reversed the circuit court's order that it lacked subject matter jurisdiction. The Supreme Court affirmed, holding (1) under Tenn. Code Ann. 27-5-106 and -107, the circuit court should have entered a default judgment against Appellant in the amount of the general sessions judgment, subject to execution in the circuit court; and (2) after the circuit court dismissed the appeal and remanded to the general sessions court, the circuit court had subject matter jurisdiction to grant Defendant's motion to set aside its prior order. View "Ken Smith Auto Parts v. Thomas" on Justia Law

The Supreme Court reversed the judgment of the court of criminal appeals and reinstated the judgment of the trial court suspending a bonding company for violating a local rule of court requiring an agent of the bonding company to be present at court appearances of defendants for whom the bonding company serves as surety, holding that the local rule is valid and enforceable.The bonding company in this case conceded that it violated the local rule but asserted that the local rule was inconsistent with Tennessee statutes and was arbitrary and capricious. The court of criminal appeals concluded that the part of the local rule requiring an agent of the bonding company to attend all court appearances was arbitrary, capricious, and illegal. The Supreme Court reversed, holding (1) the local rule does not conflict with state statutes and is not arbitrary, capricious, or unreasonable; and (2) the trial court did not err by suspending the bonding company for violating the local rule. View "In re Cumberland Bail Bonding" on Justia Law

The Supreme Court vacated the qualified protective order entered by the trial court in this case, holding that Tenn. Code Ann. 29-26-121(f) is unconstitutional as enacted to the limited extent that it divests trial courts of their inherent discretion over discovery and that the statute can be elided to make it permissive and not mandatory upon trial courts.Plaintiff filed this healthcare liability wrongful death lawsuit on behalf of the decedent alleging that Defendant's negligent treatment of the decedent resulted in the decedent's death. During discovery, Defendants filed a motion for a qualified protective order pursuant to section 29-26-121(f), which allows defense counsel to conduct ex parte interviews with patients' non-party treating healthcare providers in a healthcare liability lawsuit. In response, Plaintiff argued that the statute is unconstitutional because it deprives the trial court of its inherent authority over court proceedings. The trial court entered a written qualified protective order allowing the interviews. The Supreme Court vacated the qualified protective order, holding (1) section 29-26-121(f) impermissibly intrudes on the authority of the judiciary over procedural matters; and (2) the unconstitutional portion of the statute may be elided, and the statute as elided is constitutional. View "Willeford v. Klepper" on Justia Law

The Supreme Court answered in the negative questions of law certified from the United States District Court for the Middle District of Tennessee regarding the constitutionality of Tennessee's statutory cap on noneconomic damages, Tenn. Code Ann. 29-30-102, holding that the statutory cap does not violate the right to trial by jury, the doctrine of separation of powers, or the equal protection provisions of the Tennessee Constitution.Specifically, the Supreme Court answered (1) the noneconomic damages cap in civil cases imposed by section 29-39-102 does not violate a plaintiff’s right to a trial by jury, as guaranteed in Tenn. Const. art. I, 6; (2) the noneconomic damages cap in civil cases imposed by section 29-39-102 does violate Tennessee’s constitutional doctrine of separation of powers between the legislative branch and the judicial branch; and (3) the noneconomic damages cap in civil cases imposed by section 29-39-102 does not violate the Tennessee Constitution by discriminating disproportionately against women. View "McClay v. Airport Management Services, LLC" on Justia Law

The Supreme Court affirmed the court of criminal appeals' judgment affirming Defendant's conviction for one count of second degree murder, an alternative count of first degree felony murder, especially aggravated robbery, and three counts of aggravated assault, holding that, while the trial court erred in admitting certain testimony, substantial justice did not require that plain error relief be granted.At issue was whether the trial court committed reversible error in allowing the State to elicit testimony about a statement made by a non-testifying codefendant whose trial was severed and whose statements were the subject of a motion in limine granted by the trial court. After he was convicted, Defendant filed a motion for new trial, arguing that the trial court erred in concluding that the doctrine of curative admissibility permitted the testimony and, for the first time, raising a contention that the testimony violated his constitutional right of confrontation. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the testimony should not have been allowed, but Defendant was not entitled to plain error relief on his claim that the trial court violated his constitutional rights of confrontation by permitting the testimony; and (2) Defendant was not entitled to relief on the claims he preserved for plenary review. View "State v. Vance" on Justia Law

The Supreme Court affirmed the judgment of the court of criminal appeals affirming Defendant's conviction for burglary, holding that application of the burglary statute under the circumstances of this case did not violate due process or prosecutorial discretion.Defendant's conviction arose from her involvement in a scheme to enter a Walmart retail store, steal merchandise, and have another individual return the merchandise for a gift card. Defendant had previously been banned from Walmart retail stores for prior acts of shoplifting, and the owners of these stores had issued documents to Defendant precluding Defendant from entering the stores. The State sought an indictment against Defendant for burglary rather than criminal trespass, reasoning that Defendant entered Walmart without the effective consent of the owner and committed a theft therein. Defendant appealed her burglary conviction, arguing that the burglary statute is unconstitutionally vague as applied to the extent that it implicates due process rights. The Supreme Court affirmed, holding (1) the language of the statute criminalizing burglary is clear and unambiguous on its face; (2) the statute is not unconstitutionally vague as applied, and nothing in the statute precludes its application to the fact scenario in this case; and (3) the prosecutor did not exceed her discretion in interpreting and applying the statute. View "State v. Welch" on Justia Law

The Supreme Court vacated the criminal court's May 3, 2017 order and confirmed that the criminal court's February 3, 2012 remained intact and final, holding that the criminal court did not have authority to grant motions filed by the Tennessee Bureau of Investigation (TBI) and to modify an order dismissing criminal prosecutions several years after the order became final.On February 3, 2012, the criminal court granted Defendant's motion to dismiss Defendant's indictments for violating certain registration requirements applicable to violent sexual offenders. The criminal court based its determination that Defendant's previous Florida sexual battery conviction required him to comply only with reporting provisions relating to sexual offenders. In December 2014, the TBI filed a motion for relief from the February 3, 2012 order, arguing that the criminal court lacked authority to determine Defendant's offender classification. The criminal court agreed and partially vacated its February 3, 2012. The Supreme Court held that the criminal court had no authority to modify or partially vacate its February 3, 2012 order, except to correct clerical errors, oversights, or omissions in accordance with Tenn. R. Crim. P. 36. View "State v. Allen" on Justia Law

In this healthcare liability action, the Supreme Court affirmed the decision of the trial court denying Plaintiffs' motion to alter or amend after concluding that Plaintiffs' sole expert witness was not competent to testify on causation and granting summary judgment to Defendant, holding that the trial court's decision was within the range of acceptable alternative dispositions of the motion to alter or amend.In Plaintiffs' motion to alter or amend Plaintiffs proffered causation testimony from a new expert witness. The trial court denied the motion. The court of appeals reversed, concluding that the trial court abused its discretion. The Supreme Court reversed the decision of the court of appeals and reinstated the judgment of the trial court, holding that the court of appeals erred in holding that the trial court's denial of Plaintiffs' motion to alter or amend was an abuse of discretion because the trial court's decision was within the parameters of the court's sound discretion. View "Harmon v. Hickman Community Healthcare Services, Inc." on Justia Law

The Supreme Court reversed the judgment of the court of criminal appeals concluding that Rader Bonding Company, Inc. should have been relieved from forfeiture on a $7,500 bond in connection with Defendant's DUI charge and affirmed the court's conclusion that Rader remained obligated on a $2,500 bond in connection with Defendant's driving on a revoked license charge, holding that the trial court did not abuse its discretion when it entered a final judgment of forfeiture against Rader for the total amount of the bond.At issue was whether Rader remained obligated under a bond agreement entered on Defendant's arrest for DUI, second offense, when a subsequent indictment charged Defendant with driving under the influence, fourth offense. The Supreme Court held (1) sureties remain obligated pursuant to Tenn. Code Ann. 40-11-130(a)(1) and -138(b) and Young v. State, 121 S.W.2d 533 (Tenn. 1938); and (2) because both the driving on a revoked license and DUI charges remained the same and were not resolved by a statutory disposition that would have relieved Rader of liability on the bond, the trial court's entry of the final judgment of forfeiture against Rader was not an abuse of discretion. View "In re Rader Bonding Co., Inc." on Justia Law

The Supreme Court reversed in part the judgment of the court of criminal appeals affirming Defendant's arson conviction but reversing his conviction for presenting a false or fraudulent insurance claim, holding that the proof at trial was sufficient to support Defendant's conviction for presenting a false or fraudulent insurance claim.A jury convicted Defendant of arson and of presenting a false or fraudulent insurance claim in the amount of $10,000 or more but less than $60,000. The court of appeals affirmed Defendant's conviction of arson but concluded that the evidence was insufficient to support the false or fraudulent insurance claim conviction. The Supreme Court reversed, holding that the proof was sufficient to support the jury's conclusion that Defendant violated the false or fraudulent insurance claims statute. View "State v. Mitchell" on Justia Law