Justia Tennessee Supreme Court Opinion Summaries

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

In this defamation action, the Supreme Court affirmed the judgment of the court of appeals reversing the trial court’s order granting Plaintiff’s motion to compel Defendants, a media outlet and a reporter, to respond to discovery requests to which Defendants objected on the basis of Tennessee’s news media shield law, Tenn. Code Ann. 24-1-208(a), holding that the trial court erred by granting Plaintiff’s motion to compel.As relevant to this appeal, the court of appeals determined that (1) a showing of malice cannot defeat the fair report privilege, and (2) an assertion of the fair report privilege exempts defendants from part of the protections of the shield law. The Supreme Court affirmed on separate grounds and remanded the case for further proceedings, holding (1) neither actual nor express malice defeats the fair report privilege, the only limitations on the privilege being that a report of an official action or proceeding must be fair and accurate; and (2) the fair report privilege is a defense based upon a source of information that renders the source of the statements the plaintiff alleges to be defamatory unprotected by the shield law. View "Funk v. Scripps Media, Inc." on Justia Law

The Supreme Court reversed the order of the trial court denying Employer’s motion to dismiss Employee’s action seeking workers’ compensation benefits for injuries she received from Employer’s failure to use its automated external defibrillator (AED) while Employee suffered a non-work related medical emergency, holding that Employer was not liable for workers’ compensation benefits under the circumstances.Employee collapsed at work because of a medical condition unrelated to her employment. Employer had acquired an AED but did not use it to assist Employee while awaiting emergency medical responders. Employee brought suit, alleging that Employer’s failure to use the AED and its failure to train or hire an employee able to use an AED delayed resuscitation efforts, causing Employee to sustain a brain injury. The trial court denied Employer’s motions to dismiss. The Supreme Court reversed, holding that Employee’s claim did not arise out of her employment because Employer provided reasonable medical assistance and had no statutory or common law duty to use its AED to assist Employee. View "Chaney v. Team Technologies, Inc." on Justia Law

The Supreme Court affirmed Defendant’s convictions of the premeditated and felony murder of Clarence James and the premeditated and felony murder of Lillian James and Defendant’s sentences of death, holding that no reversible error occurred during the proceedings below.Specifically, the Court held (1) Defendant was not denied his constitutional right to counsel; (2) the trial court did not abuse its discretion in admitting into evidence certain testimony; (3) the evidence was sufficient to support Defendant’s convictions; (4) the trial court did not err in denying the appointment of a mitigation expert; and (5) Defendant’s death sentences were appropriate and not excessive or disproportionate to the penalty imposed in similar cases. View "State v. Jones" on Justia Law