Justia Tennessee Supreme Court Opinion Summaries

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

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 affirmed the court of appeals' decision reversing the trial court's grant of summary judgment in favor of 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 concluded that the city was required to distribute the tax proceeds pro rata among all schools in the county. The court of appeals reversed. The Supreme Court affirmed, holding that the distribution statute directed the city to distribute the education portion of its LBD tax proceeds in support of its own municipal school system. View "Washington County School System v. City of Johnson City, Tennessee" 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 affirmed 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 distribution 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 that the city share those proceeds with the county. View "Sullivan County, Tennessee v. City of Bristol, Tennessee" 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 reversed the decision of the court of appeals reversing the judgment of the trial court granting summary judgment against the county on its claim that the liquor-by-the-drink (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.The county in this case had not approved the LBD sales, but the city had. The Commissioner of the Tennessee Department of Revenue distributed the tax proceeds to the city. The city distributed half its tax proceeds to its own city school system. The court of appeals concluded that section 57-4-306 required the city to distribute half of its LBD tax proceeds pro rata among all schools in the county. The Supreme Court reversed, holding (1) the distribution statute directed cities to distribute half of their LBD tax proceeds for the benefit of the city's own school system; and (2) the city in this case was not required to share its LBD tax proceeds with the county or the county schools. View "Coffee County Board of Education v. City of Tullahoma" 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 affirmed the Court of Appeals' decision affirming the trial court's grant of summary judgment against the county and in favor of the two defendant cities, holding that the LBD statute, Tenn. Code Ann. 57-4-306, did not require the Commissioner of the Tennessee Department of Revenue to pay half of the cities' LBD tax proceeds to the county.The recipient cities distributed half of their tax proceeds to its own city school system and did not share the proceeds with the county. The counties sued the cities, arguing that section 57-4-306 required the cities to distribute the tax proceeds pro rata among all schools in the county based on average daily attendance. The trial court granted summary judgment for the cities. The trial court held that the statute required counties to distribute their LBD tax proceeds pro rata among all schools in the county, even though it did not require the same of cities. The court of appeals affirmed. The Supreme Court affirmed, holding holding that the distribution statute directed the cities to distribute the education portion of their LBD tax proceeds in support of their own municipal school systems. View "Blount County Board of Education v. City of Maryville, Tennessee" on Justia Law

In this case in which the district court certified a question of law to the Supreme Court regarding the interpretation of two insurance policies the Supreme Court answered that, under Tennessee law and based on the language in the policies at issue, the insurer, in making an actual cash value payment, may not withhold a portion of repair labor as depreciation.The policy defined actual cash value as "the cost to replace damaged property with new property of similar quality and features reduced by the amount of depreciation applicable to the damaged property immediately prior to the loss" and stated that "actual cash value includes a deduction for depreciation." The Supreme Court held (1) the language in the policies was ambiguous and must be construed in favor of the insured parties; and (2) therefore, labor may not be depreciated when the insurance company calculates the actual cash value of a property using the "replacement cost less depreciation" method. View "Lammert v. Auto-Owners (Mutual) Insurance Co." on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the trial court’s judgment granting a bank’s motion to dismiss this action brought by Plaintiff, holding that the allegations of the complaint were sufficient to survive the bank's motion to dismiss.Plaintiff was listed as a joint tenant with right of survivorship on the checking and savings accounts. Plaintiff brought this breach of contract action alleging that Defendant, the bank, removed his name from checking and savings accounts without his consent and breached its duty to him as co-owner of the account by accepting forged signature cards. The Supreme Court reversed the dismissal of Defendant’s motion to dismiss, holding (1) Plaintiffs sufficiently complied with Tenn. R. Civ. P. 10.03 by attaching the signature cards reflecting his status as a joint tenant with right of survivorship, which is the basis of his breach of contract claim; and (2) Plaintiff’s claims were sufficient to survive a motion to dismiss because, under Tennessee law, a contractual relationship arises between a bank and joint tenants upon the creation of joint tenancy bank accounts and no statute affords banks protection from liability for removing a joint tenant’s name from an account without the joint tenant’s consent. View "Estate of Ella Mae Haire v. Webster" on Justia Law

In this appeal from the grant of Defendant’s motion to suppress, the Supreme Court Court adopted the good-faith exception to the exclusionary rule set forth by the United States Supreme Court in Herring v. United States, 555 U.S. 135 (2009), but nevertheless affirmed the decision to suppress the evidence, holding that neither of Defendant’s arrests fell within the good-faith exception.A police officer arrested Defendant without a warrant because he was on a list of individuals who had been barred from housing authority property. Upon performing a search incident to arrest, the officer seized marijuana from Defendant. Almost three weeks later, the same officer again arrested Defendant on the same property based on the same list and again seized marijuana from Defendant. When it was discovered that the list was incorrect and that Defendant’s name should have been removed before he was arrested, the trial court suppressed the evidence in both cases. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) it is appropriate at this point to adopt the good-faith exception set forth in Herring; but (2) the facts of this case did not support application of the good-faith exception to the exclusionary rule. View "State v. McElrath" on Justia Law