Justia Tennessee Supreme Court Opinion Summaries

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

The Supreme Court accepted a question of law from the United States Court of Appeals for the Sixth Circuit and concluded that a defendant convicted of first-degree murder committed on or after July 1, 1995 and sentenced to life in prison under Tenn. Code Ann. 39-13-202(c)(3) may be released, at the earliest, after fifty-one years of imprisonment.The certified question in this case concerned the interpretation and application of the Tennessee sentencing statutes governing release eligibility of criminal defendants under Tenn. Code Ann. 40-35-501(h) and (i). After analyzing the statutes, the Supreme Court held that a defendant convicted of first-degree murder that occurred on or after July 1, 1995 may be released after service of at least fifty-one years if the defendant earns the maximum allowable sentence reduction credits. View "Brown v. Jordan" on Justia Law

The Supreme Court affirmed Defendant’s conviction for aggravated assault but modified his sentence, holding that the evidence was sufficient to support the conviction but the trial court erred in sentencing Defendant to enhanced punishment because Defendant did not receive proper notice of the State’s intention to seek enhanced sentencing.Defendant was convicted of aggravated assault and sentenced as a career offender. Defendant unsuccessfully objected to his classification as a career offender based on the State’s failure to file a pre-trial notice of intent to seek enhanced punishment. In its oral sentencing findings, the trial court noted that Defendant had the requisite prior convictions to qualify as a career offender and that, in a prior case, the State had filed a proper notice. The court of appeals affirmed. The Supreme Court reversed the sentence and remanded for entry of a corrected judgment, holding (1) a new enhancement notice must be filed in a separate case that is wholly unrelated to a prior case in which the State provides such notice; and (2) having received no properly filed notice of the State’s intent to seek enhanced punishment, Defendant was entitled to relief. View "State v. Williams" on Justia Law

The Supreme Court affirmed the judgment of the trial court dismissing death-sentenced inmates’ challenge to Tennessee’s current three-drug lethal injection protocol, holding that the inmates failed to establish that the three-drug protocol constitutes cruel and unusual punishment under the Eighth Amendment to the United States Constitution or article I, section 16 of the Tennessee Constitution.This appeal was the third time the Supreme Court addressed the facial constitutionality of Tennessee’s lethal injection protocol. In the first two appeals the Court upheld the particular protocol in question. At issue in the instant appeal was Tennessee’s current three-drug protocol. The trial court dismissed the inmates’ complaint for declaratory judgment. The Supreme Court affirmed, holding (1) the inmates failed to establish that the three-drug protocol constitutes cruel and unusual punishment; and (2) the majority of the other issues raised by the inmates on appeal were rendered moot, and the inmates were not entitled to relief on their remaining issues. View "Abdur'Rahman v. Parker" on Justia Law

The question these consolidated cases presented for the Tennessee Supreme Court's review centered on whether the trial court erred in suppressing evidence seized from the defendants’ residences in the 19th Judicial District because the warrants were signed by a Judge of the 23rd Judicial District. The Court held that, in the absence of interchange, designation, appointment, or other lawful means, a circuit court judge in Tennessee lacks jurisdiction to issue search warrants for property located outside the judge’s statutorily assigned judicial district. Nothing in the record on appeal established the 23rd Judicial District Circuit Court Judge obtained jurisdiction to issue search warrants for property in the 19th Judicial District. As a result, the searches were constitutionally invalid. The judgment of the Court of Criminal Appeals, which upheld the trial court’s order granting the defendants’ motions to suppress was affirmed. View "Tennessee v. Frazier" on Justia Law