Justia Tennessee Supreme Court Opinion Summaries

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

The Supreme Court affirmed the ruling of the trial court that documents containing communications between a corporation’s legal counsel and a property management property were protected under the attorney-client privilege, holding that the attorney-client privilege applied to the documents in this case.After acquiring commercial properties, the corporation filed unlawful detainer actions against the properties’ tenants. The tenants sought documents from the property management company that managed the corporation’s properties, but the corporation and property management company objected to producing the documents. The trial court concluded that the property management was an agent of the corporation, and therefore, the attorney-client privilege applied. The Supreme Court affirmed on different grounds, holding (1) the attorney-client privilege extends to communications between an entity’s legal counsel and a third-party non employee of the entity if the non employee is the functional equivalent of the entity’s employee; (2) the property management company in this case was the functional equivalent of the corporation’s employee; and (3) the communications related to the subject matter of counsel’s representation of the corporation and were made with the intention that they would be kept confidential. View "Dialysis Clinic, Inc. v. Medley" on Justia Law

In this breach of contract case, the Supreme Court held that, in interpreting a fully integrated contract, extrinsic evidence may be used to put the written terms of the contract into context, but it may not be used to vary, contradict, or supplement the contractual terms in violation of the parol evidence rule.Plaintiff, an insurance agency, sold insurance policies for Defendant, BlueCross BlueShield of Tennessee, Inc. Defendant paid Plaintiff commissions on the sales, and the commission arrangement was governed by a general agency agreement. Plaintiff brought this lawsuit claiming that Defendant breached the agency agreement and owed Plaintiff substantial damages. The trial court awarded Plaintiff almost $2 million in damages for Defendant’s systemic commission underpayments. The court of appeals affirmed. At issue before the Supreme Court was the use of extrinsic evidence to interpret contracts. The Supreme Court reversed in part and remanded, holding (1) Defendant only breached the parties agreement by refusing to pay commissions to Plaintiff after their agreement was terminated; and (2) the alleged systemic commission underpayments were not inherently undiscoverable. View "Individual Healthcare Specialists, Inc. v. BlueCross BlueShield of Tennessee, Inc." on Justia Law

The Supreme Court reversed Defendant’s conviction of attempted especially aggravated sexual exploitation of a minor, holding that the evidence was insufficient to support an inference that Defendant intended to record, and believed he would record, the minor victim engaged in a “lascivious exhibition” of her private body areas.In this case, Defendant hid a video camera in the minor victim’s bedroom and aimed it to record the area where the victim normally changed clothes. The victim was fully clothed when she returned to her bedroom, noticed the camera, and turned it off. Defendant was convicted of especially aggravated sexual exploitation of a minor, i.e., attempted production of child pornography. The Supreme Court reversed, holding (1) the evidence showed at most that Defendant intended to produce material that would include images of the minor victim engaged in everyday activities ordinarily performed in the nude; and (2) therefore, the evidence was insufficient to support a finding that Defendant attempted to produce material that would include a depiction of a minor in a lascivious exhibition of her private body areas, as required under Tennessee’s child sexual exploitation statutes and construed in State v. Whited, 506 S.W.3d 416 (Tenn. 2016). View "State v. Hall" on Justia Law

The Supreme Court reversed the judgment of the court of appeals and vacated the judgment of the trial court in this dispute over the enforceablility of exculpatory provisions of an agreement that released a medical transportation company from liability in transporting a patient to a doctor’s appointment, holding that the exculpatory language in the agreement did not, as a matter of law, bar the patient’s claim in this case.Before the patient was about to be transported, the medical transportation company’s driver required the patient to sign an agreement releasing the company from liability. After the appointment, the patient fell as he was getting into the company’s van. The patient sued the company, and the company filed a motion to dismiss based on the exculpatory provisions of the agreement. The lower courts held that the exculpatory provisions were enforceable and barred the patient’s claim. The Supreme Court reversed, holding (1) in determining the enforceability of an exculpatory agreement, a court should consider the totality of the circumstances and weigh three non-exclusive factors; (2) as a matter of law, the exculpatory provisions in the agreement at issue were unenforceable and did not bar the patient’s claim against the company. View "Copeland v. Healthsouth/Methodist Rehabilitation Hospital, LP" on Justia Law

The Supreme Court affirmed the judgment of the Court of Criminal Appeals affirming the decision of the trial court to revoke Defendant’s judicial diversion for refusing to admit certain facts during his sex offender treatment, holding that Defendant’s due process rights were not violated because he was not specifically informed in conjunction with his nolo contendere plea that his judicial diversion could be revoked if he refused to admit certain facts during his sex offender treatment.Defendant pled nolo contendere to one count of solicitation of a minor and was placed on judicial diversion with a one-year probationary term. Defendant was required to register as a sex offender and to participate in sex offender treatment but was discharged from his treatment program for noncompliance. Thereafter, the trial court revoked Defendant’s diversion, adjudicated him guilty, and extended his probation. The Supreme Court affirmed, holding that due process does not require that a sex offender placed on judicial diversion with a probationary period to be informed specifically in conjunction with his plea that his judicial diversion and probation may be revoked if he is discharged from sex offender treatment due to his refusal to acknowledge that he committed the elements of the offense to which he pled. View "State v. Albright" on Justia Law

At issue in this appeal was what showing, if any, a defendant must make to prevail on a motion for reduction of sentence under Tenn. R. Crim. P. 35 where the defendant pleaded guilty without an agreement as to sentencing pursuant to Tenn. R. Crim. P. 11(c)(1)(B).Defendant pleaded guilty without an agreement as to sentence. The trial court granted Defendant’s Rule 35 motion and reduced his aggregate sentence. The Court of Criminal Appeals reversed, concluding that a defendant must present post-sentencing information or developments warranting a reduction of sentence to prevail on a Rule 35 motion. The Supreme Court reversed and reinstated the trial court’s judgment, holding (1) the standard applied by the Court of Criminal Appeals is limited to Rule 35 motions seeking reduction of specific sentences imposed in exchange for guilty pleas; and (2) the trial court did not abuse its discretion when it determined that Defendant’s initial sentence was excessive and granted Defendant’s Rule 35 motion. View "State v. Patterson" on Justia Law