Justia Tennessee Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of criminal appeals reversing the trial court's ruling that Defendant's statements during a post-polygraph interview were inadmissible pursuant to Tenn. R. Evid. 403, holding that the trial court did not erroneously assess the evidence or incorrectly evaluate the danger of unfair prejudice when determining whether to exclude Defendant's post-polygraph statements under Rule 403.Specifically, the Supreme Court held that the trial court concluded the Rule 403 balancing test within the parameters of its sound discretion and that the analysis by the court of criminal appeals essentially constituted a reweighing of the evidence before the trial court and a substitution of its judgment for that of the trial court. Because this approach was contrary to the Court's abuse of discretion standard of review, the Court reversed the judgment of the court of criminal appeals and remanded the matter to the trial court for further proceedings. View "State v. McCaleb" on Justia Law

The Supreme Court reversed the judgment of the Court of Criminal Appeals declining to grant the State's request to abandon the doctrine of abatement ab initio, holding that, due to changes in Tennessee's public policy in the arena of victims' rights, the doctrine of abatement ab initio must be abandoned.During an appeal from his conviction, the defendant in this case died. The defendant's attorney filed a motion asking the Court of Criminal Appeals to apply the doctrine of abatement ab initio, which the Supreme Court adopted in Carver v. State, 398 S.W.2d 719 (Tenn. 1966). The doctrine stops all proceedings from the beginning and renders the defendant as if he or she had never been charged. The State opposed the motion and urged the appellate court to abandon the doctrine. The Court of Criminal Appeals declined to do so and abated Defendant's conviction. The Supreme Court overruled the Court of Criminal Appeals' judgment, dismissed the appeal, and reinstated the trial court's judgment, holding that the doctrine of abatement ab initio must be abandoned and that, in this case, because there was no evidence that any interest would benefit from allowing the deceased defendant's appeal to continue, the appeal should be dismissed. View "State v. Al Mutory" on Justia Law

The Supreme Court reversed the decision of the Court of Criminal Appeals affirming the judgment of the trial court convicting Defendant of felony reckless endangerment, which is not a lesser-included offense of aggravated assault as indicted in this case, holding that the mandates of Tenn. R Crim. P. 7(b)(1) were not followed in this case and that the actions of counsel did not rise to the level of causing an effective amendment to the indictment.The lower courts concluded that Defendant, through the actions of counsel, caused an effective amendment of the indictment. The Supreme Court vacated the judgment of conviction and dismissed the case, holding (1) Rule 7(b)(1) sets forth the procedure for amending an indictment with a defendant's counsel, and those mandates were not followed in this case; and (2) the actions of counsel amounted at most to acquiescence rather than an affirmative request for the trial court to consider felony reckless endangerment as a lesser offense. View "State v. Myers" on Justia Law

The Supreme Court reversed the judgment of the court of criminal appeals affirming the judgment of the trial court ruling that certain portions of the Public Safety Act of 2016 (the PSA) were facially unconstitutional on grounds of separation of powers, due process, and equal protection, holding that the constitutionality of the PSA provisions at issue was not ripe for consideration by the trial court.Defendant A.B. Price, Jr. attempted to plead nolo contendere to sexual battery, and defendant Victor Sims attempted to plead guilty to aggravated assault. The trial court declared the portions of the PSA facially unconstitutional, accepted Defendants' pleas, and inserted in each judgment the special conviction that the probated portion of defendants sentences were not subject to the PSA. The court of criminal appeals affirmed. The Supreme Court reversed, holding that the constitutional issues identified and ruled upon by the courts below were not ripe for adjudication. View "State v. Price" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the decision of the trial court granting summary judgment to an architect firm seeking to recover its design fees from a development company, holding that disputed issued of material fact existed that precluded summary judgment.Plaintiff, the architect firm, designed a condominium project for Defendant, the development company. Defendant was not able to pay Plaintiff under the contract, and as a result, Plaintiff's project agreed to accept a condominium in the project instead of a fee. Defendant did not fulfill the agreement. Thereafter, Plaintiff filed a mechanic's lien for its unpaid fee under the contract and filed suit to enforce the lien. The trial court granted summary judgment to Plaintiff, concluding that there was insufficient evidence that the parties intended a novation by substituting the agreement to convey a condominium for the contract. The court of appeals affirmed. The Supreme Court reversed, holding that summary judgment was improperly granted because disputed questions of material fact existed about whether Plaintiff and Defendant intended a novation when they executed the agreement for the condominium. View "TWB Architects, Inc. v. Braxton, LLC" on Justia Law

The Supreme Court reversed the decision of the court of appeal reversing the judgment of the trial court in favor of Defendant in this wrongful death action, holding that, under the circumstances of this case, Defendant was not liable for negligently facilitating the decedent's suicide.While staying alone in Defendant's home, the decedent, who was an adult, committed suicide by shooting herself with an unsecured gun in Defendant's home. The decedent's estate brought this action alleging that Defendant should have known that the decedent was potentially suicidal and that he negligently facilitated the suicide by failing to secure the gun. The trial court granted summary judgment for Defendant. The court of appeals reversed. The Supreme Court reversed, holding (1) the evidence was insufficient for a trier of fact to find that the decedent's suicide was a reasonably foreseeable probability; and (2) therefore, the decedent's suicide constituted a superseding intervening event that breaks the chain of proximate causation, cutting off any liability of Defendant to the estate. View "Cotten v. Wilson" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the circuit court's denial of Mother's motion seeking relief available under Tenn. R. Civ. P. 60.02(3) as to Father's post-divorce petition seeking modification of the parenting plan adopted in the parties' final divorce decree on the grounds that the circuit court lacked subject matter jurisdiction, holding that the circuit court retained subject matter jurisdiction of the post-divorce petition.The court of appeals ruled that Father's petition alleged facts that were tantamount to an unruly child claim, over which juvenile courts have exclusive original jurisdiction pursuant to Tenn. Code Ann. 37-1-103. Thereafter the General Assembly amended section 37-1-103 to expressly provide that a circuit court retains subject matter jurisdiction under the circumstances until and unless a pleading is filed or relief is sought in juvenile court and the juvenile court’s exclusive original jurisdiction is invoked. The Supreme Court reinstated the judgment of the circuit court, holding that because the General Assembly applied the amendment to certain cases, including this appeal, and because no pleading was filed in juvenile court, nor was the juvenile court's exclusive jurisdiction invoked in any other manner in this case, the circuit court retained subject matter jurisdiction of the post-divorce petition. View "Cox v. Lucas" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the circuit court's denial of Mother's motion seeking relief available under Tenn. R. Civ. P. 60.02(3) as to Father's post-divorce petition seeking modification of the parenting plan adopted in the parties' final divorce decree on the grounds that the circuit court lacked subject matter jurisdiction, holding that the circuit court retained subject matter jurisdiction of the post-divorce petition.Father's petition alleged facts that were tantamount to an unruly child claim, over which juvenile courts have exclusive original jurisdiction pursuant to Tenn. Code Ann. 37-1-103. After the Supreme Court granted this appeal the General Assembly amended section 37-1-103 to expressly provide that a circuit court retains subject matter jurisdiction under the circumstances until a pleading is filed in juvenile court or the juvenile court's exclusive jurisdiction is invoked in any other manner. The Supreme Court reinstated the judgment of the circuit court, holding that because the General Assembly applied the amendment to section 37-1-103 to all cases pending on its April 18, 2019 effective date, including this appeal, and because the juvenile court's jurisdiction was not invoked, Mother was not entitled to relief from the circuit court's orders adjudicating Father's petition. View "Minyard v. Lucas" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to suppress evidence obtained from Defendant's computer pursuant to a search warrant, holding that Tenn. Code Ann. 39-17-1007 does not require search warrants to be applied for by the office of the district attorney general.A police officer applied for and obtained the search warrant, by which pornographic images of minors were recovered from Defendant's computer. In his motion to suppress, Defendant argued that suppression was warranted because the search warrant was not applied for by the district attorney general. The trial court denied the motion to suppress. Defendant subsequently pled guilty to one count of sexual exploitation of a minor. The court of appeals affirmed. The Supreme Court affirmed, holding that the search warrant and supporting affidavit were not required to comply with Tenn. Code Ann. 39-17-1007. View "State v. Miller" on Justia Law

In this case regarding the proper distribution of liquor-by-the-drink (LBD) tax proceeds between a county and a municipality within the county, the Supreme Court affirming the decision of the court of appeals affirming the judgment of the trial court granting summary judgment against the county on its claim that the LBD tax distribution statute, Tenn. Code Ann. 57-4-306, required cities to distribute the tax proceeds as the counties distribute the county property tax schools, holding that that the city was not required to share those proceeds with the county or the county schools.The county in this case had not approved the LBD sales, but the city had. The Commissioner of the Tennessee Department of Revenue distributed tax proceeds to the city in accordance with section 57-4-306. The city distributed half its tax proceeds to its own city school system and did not share the proceeds with the county. The trial court granted summary judgment in favor of the city. The court of appeals affirmed. The Supreme Court affirmed, holding that the statute directed the city to distribute the education portion of its LBD tax proceeds in support of its own municipal school system and did not require the city to share the proceeds with the county or its schools. View "Bradley County School System v. City of Cleveland, Tennessee" on Justia Law