Justia Tennessee Supreme Court Opinion Summaries

In this case challenging the constitutionality of Tenn. Code Ann. 55-10-413(f), the Supreme Court held that the Defendant’s constitutional challenges failed.The statutory scheme at issue here imposes a fee upon persons convicted of certain drug and alcohol offenses when Tennessee Bureau of Investigation (TBI) forensic scientists have conducted chemical tests to determine blood alcohol or drug content. The statute earmarks the fees imposed to an intoxicant testing fund, and monies in the fund remain available for appropriation to the TBI as determined by the General Assembly. Defendant argued that the statutory scheme provides TBI forensic scientists with financial incentives to produce blood alcohol test results that result in convictions, which increases fees and funding for the TBI. Therefore, Defendant argued, the financial incentives create an appearance of impropriety and deprive of her her constitutional right to a fair and impartial trial. The Supreme Court held (1) the standard of neutrality announced in Tumey v. Ohio, 273 U.S. 510 (1927), and its progeny does not apply to TBI forensic scientists; (2) even if the Tumey standards applied, Defendant’s constitutional claim failed because there is no appearance of impropriety; and (3) the statute does not violate substantive due process. View "State v. Decosimo" on Justia Law

The Supreme Court held that the Exclusionary Rule Reform Act (ERRA), Tenn. Code Ann. 40-6-108, represents an impermissible encroachment by the legislature upon the Supreme Court’s authority and responsibility to adopt exceptions to the exclusionary rule and therefore violates the Tennessee Constitution’s Separation of Powers Clause.Defendant was convicted to two counts of first degree premeditated murder and other crimes. The Supreme Court affirmed Defendant’s convictions and sentences, holding (1) in light of today’s holding that the ERRA is unconstitutional, the trial court erred when it denied Defendant’s motion to suppress in reliance on the ERRA; (2) a good-faith clerical error that results in an inconsequential variation between three copies of a search warrant required pursuant to Rule 41, in and of itself, does not entitle the moving party to suppression of the evidence collected pursuant to the warrant, and therefore, the trial court properly denied Defendant’s motion to suppress under this good-faith exception; and (3) Defendant’s remaining arguments on appeal did not warrant reversal of her convictions. View "State v. Lowe" on Justia Law

The Supreme Court reversed the judgment of the trial court granting Defendant’s motion to suppress a blood sample drawn from Defendant pursuant to a search warrant because the arresting officer failed to leave a copy of the warrant with Defendant, holding that, under the facts and circumstances of this case, a good-faith exception should be applied to Tenn. R. Crim. P. 41’s exclusionary rule.The trial court granted Defendant’s motion to suppress the evidence obtained pursuant to the warrant on the basis of the exclusionary rule set out in Rule 41. The Court of Criminal Appeals affirmed. The Supreme Court reversed and remanded this matter to the trial court for further proceedings, holding that, given the specific facts of this case, a good-faith exception to Rule 41’s technical requirement that the officer executing a search warrant leave a copy of the warrant with the person searched should apply to this case. View "State v. Daniel" on Justia Law

At issue in this case was whether a Brady claim is cognizable in the context of a petition for writ of error coram nobis and whether Appellant’s petition for a writ of error coram nobis should be dismissed as time-barred even though the State was not brought into the coram nobis proceedings at the trial court level and, consequently, did not assert the statute of limitations as an affirmative defense in the trial court. Appellant filed a coram nobis petition alleging that the State committed a Brady violation. The trial court dismissed Appellant’s petition in part because it was filed after expiration of the statute of limitations. The Court of Criminal Appeals affirmed because the petition did not present newly discovered evidence warranting coram nobis relief. The Supreme Court affirmed, holding (1) an error coram nobis proceeding is not the appropriate procedural vehicle for obtaining relief from an alleged Brady violation; (2) timeliness under the statute of limitations is an essential element of a coram nobis claim that must be demonstrated on the face of the petition; (3) the facts supporting an equitable tolling request must likewise appear on the face of the petition; and (4) the trial court did not err in dismissing the coram nobis petition in this case. View "Nunley v. State" on Justia Law

The Supreme Court reversed the ruling of the chancery court reversing the decision of a hearing panel denying Attorney’s petition to be reinstated to the practice of law in Tennessee following his disbarment and ordering Attorney reinstated, holding that the chancery court misapplied the applicable standard of review.In 2007, Attorney pleaded guilty to federal charges of receipt and possession of images depicting child pornography. In 2008, Attorney consented to his disbarment. In 2014, after he was discharged from prison and while on probation, Attorney petitioned to be reinstated to the practice of law. The Board of Professional Responsibility opposed the petition. The Supreme Court held that substantial and material proof supported the panel’s conclusion that Attorney had failed to prove by clear and convincing evidence his moral qualifications for reinstatement, and that the chancery court impermissibly reweighed the evidence in the record before it. View "Smith v. Board of Professional Responsibility" on Justia Law

Plaintiff’s claim brought against Defendant pursuant to the Uniformed Services Employment and Reemployment Rights Act of 1994, 38 U.S.C. 4301 to 4335 (USERRA), accrued prior to July 1, 2014 and remained barred by sovereign immunity.In 2014, the General Assembly enacted a statute waiving Tennessee’s sovereign immunity for claims bought against the State pursuant to USERRA. The waiver of sovereign immunity became effective on July 1, 2014 and applied to USERRA claims accusing on or after that date. Relying on this newly enacted statute, Plaintiff brought a USERRA claim against Defendant, an entity of the State, based on facts that occurred prior to August 8, 2014. the trial court dismissed the claim, concluding that the claim remained barred by sovereign immunity because it accrued prior to July 1, 2014. The court of appeals reversed, concluding that Plaintiff’s cause of action accrued on July 1, 2014 when Plaintiff gained a judicial remedy by the enactment of the statute waiving sovereign immunity. The Supreme Court reversed, holding that Plaintiff’s claim accrued prior to July 1, 2014. View "Smith v. Tennessee National Guard" on Justia Law

A trial court, after the abatement of a divorce action, may remedy a violation of the statutory injunction imposed by Tenn. Code Ann. 36-4-106(d)(2), which prohibits parties after a divorce complaint is served from changing the beneficiary on any life insurance policy that names either party as the beneficiary, by considering the equities of the parties.After suing Bryan Olson for divorce, Jessica Olson changed the beneficiary on her life insurance policy from Bryan to her mother, Rose Coleman. After Jessica died, Rose collected the life insurance benefits. Rose then sued Bryan for grandparent visitation. Bryan responded that he did not oppose visitation and countersued to recover the life insurance benefits. The trial court (1) awarded the insurance benefits to the Olsons’ child, finding that Jessica had intended to substitute the child as the beneficiary, and (2) awarded Rose grandparent visitation. The court of appeals (1) awarded Bryan the life insurance benefits based on Jessica’s violation of the statutory injunction, and (2) reversed the visitation award. The Supreme Court reversed in part and remanded, holding (1) the Olsons’ divorce action abated when Jessica died, and the statutory injunction Jessica violated became ineffective; and (2) Rose was not entitled to court-ordered grandparent visitation absent Bryan’s opposition to visitation. View "Coleman v. Olson" on Justia Law

At issue in this dissenters’ rights case was the methods by which a trial court may determine the “fair value” of shares of a dissenting shareholder under Tennessee’s dissenters’ rights statutes, Tenn. Code Ann. 48-23-101, et seq.The Supreme Court overruled Blasingame v. American Materials, Inc., 654 S.W.2d 659 (Tenn. 1983), to the extent Blasingame implicitly mandates use of the Delaware Block method for determining the fair value of a dissenting shareholder’s stock and adopted the more open approach set forth in Weinberger v. UOP, Inc., 457 A.2d 701, 712-13 (Del. 1983), which departs from the Delaware Block method and permits fair value to be determined by using any technique or method that is generally acceptable in the financial community and admissible in court.Defendant minority shareholders were forced out of a corporation as a result of a merger. The corporation sought a determination as to the fair value of the minority shareholders’ stock. The trial court may have based its decision to discredit the testimony of the dissenting shareholders’ expert on the basis that Blasingame compelled use of the Delaware Block method to determine stock value. The Supreme Court remanded the case to the trial court to reconsider its valuation determination in light of this decision to partially overrule Blasingame. View "Athlon Sports Communications, Inc. v. Duggan" on Justia Law

In this case alleging health care liability claims, the trial court erred by allowing Plaintiff to amend her complaint after the expiration of the statute of limitations to substitute as a defendant a health care provider to which Plaintiff had not sent pre-suit notice.The Supreme Court reversed the decisions of the trial court and court of appeals, holding that Plaintiff did not comply with the mandatory pre-suit notice provision of the Tennessee Health Care Liability Act, Tenn. Code Ann. 29-26-121(a)(1), because she did not give written pre-suit notice of the potential claim to the health care provider she later sought to substitute as a defendant after the expiration of the statute of limitations. View "Runions v. Jackson-Madison County General Hospital District" on Justia Law

In this case alleging health care liability claims, the trial court erred by allowing Plaintiff to amend her complaint after the expiration of the statute of limitations to substitute as a defendant a health care provider to which Plaintiff had not sent pre-suit notice.The Supreme Court reversed the decisions of the trial court and court of appeals, holding that Plaintiff did not comply with the mandatory pre-suit notice provision of the Tennessee Health Care Liability Act, Tenn. Code Ann. 29-26-121(a)(1), because she did not give written pre-suit notice of the potential claim to the health care provider she later sought to substitute as a defendant after the expiration of the statute of limitations. View "Runions v. Jackson-Madison County General Hospital District" on Justia Law